October 1, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11of the Federal

Aviation Regulations from: 14CFR 21subpart H; 14CFR 45.23(b); 14CFR 61.113(a) and (b); 14

CFR 91.7(a); 14CFR 91.9(b)(2); 14CFR 91.103; 14CFR 91.109; 14CFR 91.119(c); 14CFR

91.121; 14CFR 91.lSl(a); 14CFR 91.203 (a) and (b); 14CFR 91.405 (a); 14CFR 91.407 (a) (1) 14

CFR 91.409 (a)(1) and (2); 14CFR 91.417(a) and (b).

Dear Sir or Madam:

Tel-Tec Security Systems Inc., respectfully requests an exemption from several provisions of Title 14 

of the Code of Federal Regulations (C.F.R.), specifically portions of 14 C.F.R. Parts 45 and 91, to 

permit the use of our small Unmanned Aerial System (UAS), the Monarch Ag, for use in aerial survey 

of agriculture plots in remote and rural areas of the United States.

Granting an exemption is consistent with Congress’ intent, as reflected in Section 333 of the FAA 

Modernization and Reform Act of 2013, that safe systems be permitted in the National Airspace (NAS) 

prior to the issuance of final regulations governing general use of these small unmanned aerial systems.

Tel-Tec Security Systems Inc. owns and operates a Monarch One UAS which is an all-environment, 

electric-powered, self-launched, small multirotor UAS that, depending on its payload, is capable of 

collecting airborne images and location information to a Ground Control Station (GCS). It can also 

conduct high-resolution photogrammetry or perform Light Detection and Ranging (LIDAR) data 

collection. If used for high-resolution photographs or LIDAR data, the Monarch One stores the 

photographs and imagery data onboard and makes it available for download after completion of the 

flight. The Monarch One has a maximum weight of 15 pounds and a diameter of 51.5 inches, with a 

maximum cruising speed of 15mph. It is battery powered, has a maximum flight time between twenty 

(20) and twenty five (25) minutes, and can operate in temperatures ranging from 14°F to 122°F. The 

Monarch one has two omni- directional antennas, a primary and a redundant backup. The primary 9.5 

MHz antenna has a range of 6.2 miles, and the 2.4 GHz backup antenna has a range of 1.4 miles

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act")

and 14CFR Part 11,Tel-Tec Security Systems, Inc., operator of an Unmanned Aircraft System

(UAS), hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to

allow commercial operation of its UAS,so long as such operations are conducted within and under

the conditions outlined herein or as may be established by the FAA as required by Section 333.
Commercial operation of an UAS, as described herein, which are equipped with camera(s) and 

sensors, would operate in the following manner:

1. Aerial photography and/or video for public and/or private use including real estate,

architecture, land surveying, engineering and other related professional activities.

2. Aerial video and/or photography for public and/or private use including television, public

events, cinematography and news gathering.

3. Aerial inspection/photography of residential/commercial structures under contract with

the owners or local government authority.

4. Aerial inspection/photography of residential/commercial utility infrastructure including

but not limited to electrical power lines, wind turbines and cell towers.

5. Aerial video/photography or providing live video feed to assist with search and rescue

operations in cases of an emergency or natural disaster only when the local authorities or

government has requested it by contract or donation.

6. The ability to offer training to persons individually or belonging to both private and/or

public organizations that have interests in the use and application of a UAS for the purpose

of the safe operation of a UAS to enhance the safety of the National Airspace System

(NAS) as well asfor the protection of the persons and property.

As described fully below, the requested exemption would permit the operation of a UAS under

controlled conditions in the NAS that would be a) limited, b) controlled, c) predetermined and

d) will provide safety enhancements to the already safe operations in the industry presently using

conventional aircraft. 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."

The name and address of the applicant is:

Tel-Tec Security Systems, Inc

Attn: Morgan Clayton

Ph# (661) 397-5511

Email: Morgan.clayton@tel-tec.com

Address: 5020 Lisa Marie Court, Bakersfield, CA 93313

Regulations from which the exemption is requested: 

14CFR Part 21subpart H

14CFR 45.23 (b)

14CFR 61.113 (a) & {b)
14 CFR 91.7 (a)

14CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14CFR 91.119 (c)

14CFR 91.121

14CFR 91.151 (a)

14CFR 91.203 (a) & (b)

14CFR 91.405 (a)

14CFR 91.407 (a) (1)

14CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b)

Tel-Tec Security Systems, Inc. proposes to operate a UAS, the Monarch 1 (MMMMMMM) as

specified below:

Monarch is an industry leader in small UAS production. Monarch UASs are loaded with ground

breaking software enabling the user to set parameters which will not allow flight into controlled

airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude

as well as limit flight to a predetermined and set distance. In addition, Monarch software provides

real-time altitude and location information to the PIC via the linked monitor telemetry device.

Monarch One Specifications

Aircraft Model Monarch One

Weight (Battery Included) -15lbs

HoveringAccuracy (GPSMode)-Vertical: 2.5m;Horizontal: 2.5m Max Angular Velocity- Pitch:

90°/s; Yaw: 90°/s

Max Tilt Angle - 45°

MaxAscent Speed 1.25 m/s – Max Descent Speed .5 m/s

Max Speed -15 mph

Max Flight Altitude -4500m 

Max Flight Time -Approximately 20-25minutes

MotorModel–Avroto 3515 Propeller Model –APC 16x4.5 MR

Operating Temperature Range -14°F to 122°F

Dimensions –51.5."x 51.5%"x 18"

Transmitter

OperatingFrequency- 2.4 GHz; 2.400-2.483GHz

Communicating Distance (unobstructed) - 805m OutputPower-9W

Operating Temperature Range -14°F to 122°F

Given the small size of the UAS and the controlled environment provided the proposed operations

will adhere to the Reform Act's safety requirements. The approval of this application presents no

nationalsecurity issues. Regarding the level of safety surrounding the proposed operations and the

public benefit, reduction in environmental impacts, including but not limited to reduced emissions

and noise, the grant of the requested exemption is in the public interest. Accordingly the applicant

requests that the FAA grant the requested exemption with minimum delay.
AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because

operations will further enhance the safety of the persons and/or property using conventional

aircraft. These limitations and conditions to which the applicant agrees to adhere to when

conducting commercial operations under the FAA issued exemption as set forth in the Flight

Operations Manual (FOM) include:

1. Aircraft shall weigh less than 55 pounds including payload.

2. The UA will not be operated at a speed exceeding 87 knots (100 miles per hour). In no case

will the UA be operated at airspeeds greater than the maximum UA operating airspeed

recommended by the aircraft manufacturer.

3. The UA will be operated at an altitude of no more than 400 feet above ground level (AGL).

Altitude must be reported in feet AGL.

4. The UA will be operated within visual line of sight (VLOS) of the PIC at all times and the

PIC to be able to use human vision unaided by any device other than corrective lenses, as

specified on the PIC's FAA-issued airman medical certificate or U.S. driver's license.

5. All operations will utilize a visual observer (VO). The UA will be operated within the visual

line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the

VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC

must be able to communicate verbally at all times; electronic messaging or texting is not

permitted during flight operations. The PIC will be designated before the flight and cannot

transfer his or her designation for the duration of the flight. The PIC must ensure that the VO

can perform the duties required of the VO.

6. 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 prior to conducting further operations under this exemption. Functional

test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from

other people. The functional test flight must be conducted in such a manner so as to not pose

an undue hazard to persons and property.

7. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation.

8. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the UAS is in

a condition for safe flight. The pre-flight inspection will account for all potential 

discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a

condition that affects the safe operation of the UAS, the aircraft is prohibited from operating

until the necessary maintenance has been performed and the UAS is found to be in a

condition for safe flight.
9. The operator will follow the UAS manufacturer's maintenance, overhaul, replacement,

inspection, and life limit requirements for the aircraft and aircraft components.

10. The UAS operator will comply with all manufacturer safety bulletins.

11. The PIC will hold either an airline transport, commercial, private, recreational, or sport pilot

certificate. The PIC will also hold a current FAA airman medical certificate or a valid U.S.

driver's license issued by a state, the District of Columbia, Puerto Rico, a territory, a

possession, or the Federal Government. The PIC will also meet the flight review requirements

specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot

certificate.

12. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to

safely operate the UAS in a manner consistent with how the UAS will be operated under this

exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from persons, vessels, vehicles and structures. PIC qualification flight hours and

currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the

purposes of training the operator's PICs and VOs (training, proficiency, and experiencebuilding) and determining the PIC's ability to safely operate the UAS in a manner consistent

with how the UAS will be operated under this exemption are permitted under the terms of

this exemption. However, training operations may only be conducted during dedicated

training sessions. During training, proficiency, and experience-building flights, all persons not

essential for flight operations are considered nonparticipants, and the PIC must operate the

UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91. 119.

13. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All

operations must be conducted under visual meteorological conditions (VMC). Flights under

special visual flight rules (SVFR) are not authorized.

14. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with

an ARP, the center of the airport symbol as denoted on the current FAA-published

aeronautical chart, unless a letter of agreement with that airport's management is obtained or

otherwise permitted by a COA issued to the exemption holder. The letter of agreement with

the airport management must be made available to the Administrator or any law enforcement

official upon request.

15. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PIC.

16. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property.

17. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. The PIC

is prohibited from beginning a flight unless (considering wind and forecast weather

conditions) there is enough available power for the UA to conduct the intended operation and

to operate after that for at least 5 minutes or with the reserve power recommended by the

manufacturer if greater.
18. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations

shall be conducted in accordance with an ATO-issued COA.

19. All aircraft operated will 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.

20. Documents used by the operator to ensure the safe operation and flight of the UAS and any

documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the

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

21. These documents must be made available to the Administrator or any law enforcement

official upon request.

22. The UA must remain clear and give way to all manned aviation operations and activities at all

times.

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

24. All Flight operations must be conducted at least 500 feet from all nonparticipating persons,

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises where

nonparticipating persons leave such protection and are within 500 feet of the UA, flight

operations must cease immediately in a manner ensuring the safety of nonparticipating 

persons and

b. The owner/controller of any vessels, vehicles or structures has granted permission

for operating closer to those objects and the PIC has made a safety assessment of the risk

of operating closer to those objects and determined that it does not present an undue

hazard.

25. The PIC, VO, operator trainees or essential persons are not considered nonparticipating

persons under this exemption.

26. All operations shall be conducted over private or controlled-access property with permission

from the property owner/controller or authorized representative. Permission from property

owner/controller or authorized representative will be obtained for each flight to be conducted.

27. 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.

28. For operations for the purpose of closed-set motion picture and television filming and 

production, the following additional conditions and limitations apply.
29. The operator must have a motion picture and television operations manual (MPTOM)

documented as follows:

30. At least 3 days before aerial filming, the operator of the UAS must submit a written Plan of

Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area

of proposed filming. The 3-day notification may be waived with the concurrence of the

FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted under

this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of the

UAS;

d. Make, model, and serial or N-Number of UAS to be used;

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

f. A statement that the operator 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;

g. Signature of exemption holder or representative; and

h. 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 altitude essential to

accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting

to be involved and necessary for the filming production, as specified in the exemption holder’s 

MPTOM.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H,

entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of

airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating

area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21Subpart 

H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the

Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act

both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, 

upon consideration of the size, weight, speed, operational capability, and proximity to airports and

populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that

the UAS operated without an airworthiness certificate, in the restricted environment and under the

conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or

rotorcraft) operating with an airworthiness certificate without the restrictions and conditions

proposed. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot

nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively

within a secured and designated area. Unlike other civil aircraft, operations under this exemption 

will be tightly controlled and monitored by both the operator and under the requirements and in
compliance with local public safety requirements. These safety enhancements provide a greater

degree of safety to the public and property owners than conventional operations conducted with

airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these

same criteria demonstrates that there is no credible threat to national security posed by the UAS,

due to its size, speed of operation, location of operation, lack of explosive materials or flammable 

liquid fuels, and inability to carry a substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires:

When marks include only the Roman capital letter "N" and the registration number is displayed

on limited, restricted or light-sport category aircraft or experimental or provisionally certificated

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or

pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited,"

"restricted," "light-sport," "experimental," or "provisional," as applicable. Even though the UAS

will have no airworthiness certificate, an exemption may be needed as the UAS will have no

entrance to the cabin, cockpit or pilot station on which the word “experimental" can be placed.

Given the size of the LIAS, two-inch lettering will be impossible. The word "Experimental" will

be placed on the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the UAS marked on itsfuselage as

required by §45.29 (f) where the pilot, observer and others working with the UAS will see the

identification of the LIAS as "Experimental."

14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in

Command.

Pursuant to 14CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a

pilot in command of an aircraft that is carrying passengers or property for compensation or hire.

Tel-Tec Security Systems Inc. may achieve an equivalent level of safety as achieved by current

Regulations because the applicant's UAS do not carry any pilots or passengers nor property. The

risks attendant to the operation of LIAS isfar less than the risk levels inherent in the commercial

activities outlined in 14CFR 61.The PICofthe UAS will have a Private Pilot's License along with a

current State of California Driver’s License complying with the current safety levels in relation to

14 CFR 61.113 (a) & (b). Ifeel the operation and limitations set forth in the FOM will equate to the

safe operation of the UAS.

14C.F.R.§91.7(a): Civil Aircraft Airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy

condition. As there will be no airworthiness certificate issued for the aircraft, should this

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given

the size of the aircraft for maintenance and use of safety check lists prior to each flight an

equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... (2) For which
an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is

available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual

material, markings, and placards, or any combination thereof. The UAS, given its size and

configuration has no ability or place to carry such a flight manual on the aircraft, not only because

there is no pilot on board, but because there is no room or capacity to carry such an item on the

aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the

ground control point where the pilot flying the UAS will have immediate access to it.

14 C.F.R. § 91.103: Preflight Action.

This regulation requires each pilot in command to take certain actions before flight to insure the

safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft 

an exemption will be needed. The PIC will take all actions as stated in the FOM in Section 4

under Normal Procedures including but not limited to reviewing weather, flight battery

requirements, landing and takeoff distances and aircraft performance data before initiation of

flight.

14 C.F.R.§91.109: Flight Instruction.

Section 91.103 provides that no person may operate a civil aircraft (except a manned free

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual

controls. UAS and remotely piloted aircraft, by their design do not have fully functional dual

controls. Flight control is accomplished through the use of a control box that communicates

with the aircraft via radio telemetry communications. The FAA has approved exemptions for 

flight training without fully functional dual controls for a number of aircraft and for flight

instruction in experimental aircraft. The equivalent level of safety provided by the fact that

neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the

aircraft.

14C.F.R.§91.119: Minimum Safe Altitudes.

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 UAS that is a helicopter and the exemption requests authority to operate at

altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is

planned, an exemption may be needed to allow such operations. As set forth herein, the UAS will

never operate at higher than 400 AGL with the exception that in circumstances where the UAS is

used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be

operated more than 200 feet above the highest point on the structure. It will however be operated

in a restricted area with security perimeter, where buildings and people will not be exposed to

operations without their pre-obtained consent. The equivalent level of safety will be achieved

given the size, weight, 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 or local officials. Because of the advance

notice to the property owner and participants in the filming activity, all affected individuals will
be aware of the planned flight operations. Compared to flight operations with aircraft or

rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable

fuel, any risk associated with these operations is far less than those presently presented with

conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations of

the UAS will ensure separation between these UAS operations and the operations of conventional

aircraft that must comply with Section 91.119.

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 UAS may not have a barometric altimeter, but

instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be

achieved by the operator, pursuant to the safety check list and live flight data monitoring,

confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight inVFR 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 UAS provides approximately 30 minutes of powered flight. To meet the 30

minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 15

minutes in length. Given the limitations on the UAS's proposed flight area and the location of its

proposed operations within a predetermined area, a longer time frame for flight in daylight or

twilight VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR

§91.151(a) falls within the scope of prior exemptions. Operating the 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.

Additionally, limiting UAS flights to 15 minutes would greatly reduce the utility for which the

exemption will be granted.Applicant believesthat an equivalent level ofsafety can be achieved

by limiting flightsto 30 minutes or 25% of battery power- whichever happensfirst.This

restriction would bemore than adequate to returnthe UASto itsplanned landingzone from

anywhere initslimitedoperating area.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within it

the following:

(1) An appropriate and current airworthiness certificate....

(b) No person may operate a civil aircraft unless the airworthiness certificate required by

paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at
the cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded 

weighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is no ability

or place to carry certification and registration documents or to display them on the UAS. An

equivalent level of safety will be achieved by keeping these documents at the ground control

point where the pilot flying the UAS will have immediate access to them, to the extent they are

applicable to the UAS.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 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

section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not

apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight

manual and operating handbook. An equivalent level of safety will be achieved because the UAS

is very limited in size and will carry a small payload and operate only in restricted areas for a

limited period of time. If mechanical issues arise the UAS can land immediately and will be

operating from no higher than 400 feet AGL. 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 isthe person most familiar with the aircraft and best suited to

maintain the aircraft in an airworthy condition to provide the equivalent level of safety. An

equivalent level of safety will be achieved because maintenance and inspections will be performed

in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operator

will ensure that the UAS is in working order prior to initiating flight and perform required

maintenance needed.

AdditionalInformation

The applicant, Tel-Tec Security Systems, Inc. has one commercial rated MEL CFI Pilot under 

contract and two private pilots in its employ. The two private pilots both currently hold a SEL,

Private Pilots Certificate, one pilot with an Instrument rating. All three Pilots have an in-depth 

understanding of the capabilities and safety concerns involved in using this technology as an asset

to the community. Satisfaction of criteria provided in Section 333 of the Reform Act of 2012

provide more than adequate justification for the grant of the requested exemptions allowing the

commercial operation of the applicant's UAS.

Sincerely,

Morgan E. Clayton, President,

Tel-Tec Security Systems, Inc.

5020 Lisa Marie Court.

Bakersfield Ca. 93313