531 Bonnie Lane, Elk Grove Village

, IL 60007 * 312.376.3120 * www.go tst .com

Total Service Telecom, Inc. 1 | P a g e December 1 4 th , 2015

U.S

. Department of Transportation (DOT) Unmanned Aircraft S

ystems Office 1200 New Jersey Avenue, SE

Room W12

- 140, West Building Ground Floor Washington, DC 20591

RE: Petition for Section 333 Exemption

To Whom It May Concern

,

In accordance with the guidelines for submitting a petition for exemption under Section 333 of the FAA

Modernization and Reform Act of 2012

, Total Service Telecom, Inc

. , hereinafter referred to as

“ Petitioner ”, respectfully submit s its exemption request.

The Petitioner requests exemptions to legally operate Unmanned Aircraft Systems in the National Airspace System with purposes of conducting telecommunications and utility structure in spection, construction, and maintenance services, specifically; capturing aerial views and video recordings of cell carrier antennas, coax/fiber lines, remote radio units, and cellular dishes secured to vertical structures

utilized in the telecommunication s industry. Video and related data captured from the flights will be used to; verify proper installation of equipment on structures during audits, report damage to the structure and the existing equipment, inspect FAA mandated tower strobe lights and the p ossible “ nesting” of these beacons by improperly positioned antennas to ensure telecom companies stay in NEPA (National

Environmental Protection Act) compliance. All flights will be conducted under controlled conditions in cellular tower airspace that is: (i) limited, (ii) predetermined, (iii) and subject to controlled access through

Petitioner s customers and property owners.

The construction and maintenance of communication towers is highly spe cialized work. This work often

i nvolves workers climbing the towers via ladders , climbing pegs or a combination thereof. Workers also climb towers to perform maintenance activities such as painting structural steel members, changing light bulbs, and troubleshooting malfu nctioning equipment. During the performance of work activities involving communication towers, workers are exposed to a variety of serious hazards, including fall hazards, hazards associated with structural collapses, struck

- by hazards, hazards associated with worke r fatigue, radio frequency hazards, hazards associated with inclement weather (including extreme heat and cold), electrical hazards, and cut and laceration hazards due to the use of sharp, heavy tools and materials.

Work on communication towers often invo lves complex business relationships among multiple companies. Dedicated tower companies, rather than broadcast or cell phone companies (carriers), own many communication towers . The tower companies then lease space on the towers to wireless carriers.

When a carrier needs to undertake a large

- scale installation or upgrade project, it will contract with a construction management company (called a "turfing vendor"). The turfing vendor typically hires specialized subcontractors to perform specific elements of t he project, and those subcontractors mayTotal Service Telecom, Inc. 2 | P a g e

further contract with other companies to perform some of the work. It is not uncommon to have as many as six or seven layers of subcontractors between the carrier and the company that employs the workers

who actuall y perform the work (or certain parts of the work). This business structure poses challenges to setting and enforcing safety rules and ensur ing the well

- being of employees, and gives companies like cell carriers a powerful incentive to avoid any role in wor ker safety.

A search of OSHA's Integrated Management Information System (IMIS) database for both fatal and non

fatal incidents involving communication towers revealed 107 incidents from 2003 through 2013 (Docket

ID OSHA

- 2014

- 0018

- 01). These incidents res ulted in 91 fatalities and 17 injuries. Most of the fatalities (79) were due to falls. Structural collapses killed an additional eight people. Three fatalities involved electrocutions, and the last fatality was due to an employee being struck by a load whi le working on the tower. According to the IMIS data, falls were also the leading cause of injuries among communication tower workers, with 13 of 17 injuries resulting from falls (Docket ID OSHA

- 2014

- 0018

- 01). This data

includes incidents that occurred as a direct result of working on or with a communication tower. Incidents at communication tower worksites resulting from unrelated factors, such as a crane tipping over due to bad ground conditions, are not included. Moreover, these figures probably do not in clude all incidents tha t
occurred in the relevant time

- period, as they are derived solely from OSHA investigation data. The IMIS database, for example, will not include incidents that involve individuals not covered by OSHA, e.g., the

self

- employed. The cu rrent IMIS database generally includes incidents only when they involve at least one fatality or three or more hospitalizations.

Through use of a UAS, Petitioner will be able to provide services that limit the number of tower climbers needed for a given s cope of work. This in turn, will reduce the risk for injury and potentially save lives. Using a UAS, Petitioner will be able to observe and acquire valuable data for customers, thus minimizing hazardous work environments tower climbers are subjected to in order to collect the data. Using the UAS, Petitioner will prevent unnecessary climbs currently required for tower inspections and keep climbing purposes to installation/repair. The essence of this petition is to improve safety at the cell tower location

b y eliminating unnecessary climbing which is currently the only solution utilized for visual inspection purposes within the industry.

UAS’s have a vital role in preserving the integrity of the National Airspace System. Lightni ng strikes can damage the tower and its equipment, including power components attached to the structures as well as the ground equipment. Lightning strikes can also affect the strobe lighting on the tower. Strobe lighting identifies structures in darkness or bad weather for low fly ing airplanes and aircrafts. Without properly functioning strobe lighting, low flying aircrafts are at risk of hitting structures. Sending a UAS to view and record the physical status of structures saves multiple trips up and down the tower, which is curre ntly the only remedy. In addition to structural observations, the UAS will inspect equipment shelters, battery cabinets, ice

- bridges, and surrounding areas. By viewing these items, damage can be reported quickly and efficiently providing workers with an ac curate account of the work environment. With information gathered from a UAS flight, companies can make informed decisions regarding the scope of work required before entering the job site.

The UAS will also be observing customer specific antenna arrays or RAD centers on structures. New antenna array locations can be determined, and if the UAS is positioned successfully, the mechanical

down

- tilt of the antennas can be measured, thus eliminating a tedious scope of work typically tasked to

tower climbers. A lthough cell towers are highly restricted areas and the potential for consumers or bystanders to be in the area is very low, for every flight that Petitioner performs, all the aforementioned parameters will be inspected for customers, consumers, and possib le observers while maintaining proper safety measures.Total Service Telecom, Inc. 3 | P a g e

UAS Operational Characteristics

 The weight of the UAS is less than 5 lbs. with a maximum ascent speed of 5 m/s and a descent speed of 3 m/s. The aircrafts maximum flight speed is 16 m/s.

 The aircraft s vertical and horizontal aspect concerning hovering accuracy is +/

- 10cm and +/

- 1m respectfully.

 The aircrafts stabilization is 3 axis

– pitch, roll and yaw.

 The aircraft’s diagonal size (including propellers) is 590mm in length.

 The tilting range of the aircrafts gimbal is between

- 90° and +30°.

 The aircraft’s maximum operating distance in an open area for the remote controller is 2000m.

 The remote has an operating frequency of 2.400 GHz and 2.483 GHz.

 The CE and FCC compliance transmitting power (EIRP) of the remote controller is 16dBm and 20dBm respectfully.

 The remotes working current and voltage is 1.2A @ 7.4V and runs off 6000mAh LiPo 2S battery.

 The aircraft runs off a 4480mAh Li

- Po battery.

 The aircraft’s maximum flight time is approximately 23 minutes.

 The mounted camera has a resolution of 12.76 megapixels and a Field Of View (FOV) of 94° 20mm (35mm format equivalent f/28, focus at ∞).

 The sensor size of the camera is a 1/2.3" and supports HD video recording as well as RAW and JPEG photo formats.

 The phone application will work on Apple iOS 6.0 or above and Android system 4.0 and above. Tablets running these operating systems will also be supported, but not recommended. The phone application will operate as the First Pe rson Viewer (FPV) for the aircraft.

Operating Procedures

 The Pilot In Command (PIC) and potential observers will be required to wear hard hats, safety vests, and safety glasses to protect the head and eyes from potential mishaps during given operationa l flights including training or testing of the UAS.

 The PIC is required to obtain skills necessary to operate the UAS including evasive and emergency maneuvers and maintaining distances from people, vessels, vehicles, and stru c tures.

 All flights wi ll require a visual observer (VO) to be present to accompany the PIC during operation of the UAS. The PIC will be responsible for ensuring the VO can perform the functions described in the UAS operating documents. The UAS w ill be operated only within Visual Line of Sight (VLOS) of both the PIC and VO at all times. The VO will not be operating the UAS at any

time.

 The PIC will be responsible for determining whether the aircraft is in a condition for a safe flight. Only the PIC can determine if conditions are safe for flight includ ing reviewing weather, flight battery requirements, landings, and take

- off distances and aircraft performance data before initiating flight. All maintenance and alterations will be documented and an entry made in the flight aircraft records accordingly.

 Relevant materials will be kept in a location accessible to the PIC in compliance with current regulations during every flight.

 The flight area of the UAS will be observed for best takeoff and landing locations. Desired conditions include, flat and level s urfaces clear of debris, at least 15ft from power lines and structures, and a minimum distance of 12ft from the PIC and observers.

 The UAS will also be in the VLOS to both the PIC and potential observers and authorized personnel dur ing all flights.Total Service Telecom, Inc. 4 | P a g e

 Flights must take place during good weather conditions with no rain, low laying clouds, or heavy winds. All flights will take place during daylight hours with no evening or late night flights.

 The PIC will have at minimum 7 training hour s or 15 flights accrued before being designated working flights around cellular communication towers.

 The UAS will have safety bumpers, sold by the manufacturer, installed around the propellers to protect the propellers, structures, and persons from damage and injury.

 All batteries must be charged completely before each flight and each flight must end whe n the battery has a 25% power level remaining.

 A visual safety inspection will occur before each flight, testing propeller tightness, lens cap removals, proper installation of bumper guards, securing mobile devices onto the remote, and ensuring proper saf

ety equipment is displayed clearly to PIC and observers.

 The UAS will be flown under a height of 400 ft AGL and in less than a 10,000 square feet area.

 No operator or potential observer will engage in, nor may an operator or potential observer permit, an y activity during a critical phase of flight to ensure that the UAS is in a condition for safe flight operation and in a configuration appropriate for the purpose of the intended flight.

 If there is more than just an operator at a site during a flight, th e operator and authorized personnel will maintain verbal communication with each other during all operations; if unable to

maintain verbal communications, or if any condition occurs that may otherwise cause the operation to be unsafe, the operator will imm ediately conclude the operation.

 If the communication link is lost, the UAS will go into failsafe mode and safely descend to its designated home

- point location. If the communication link is reconnected during fail

- safe mode, control of the UAS can be rega ined before landing occurs at the home

- point location.

 There is no fuel or payload to the UAS, therefore there will be no potential explosives, or risk of explosion if a crash occurs with the UAS.

 The UAS will feature a built in compass that will be reca librated at every site to maintain accurate directional readings. The compass will also help in keeping the UAS stable during flights.

 The UAS will record GPS location data once “ready to fly” status is obtained. A minimum of 6

satellites will activate th e “ready to fly” status.

 T he UAS will not be operated in any moving device or vehicle at any time.

Information Supporting this Petition as Specified in 1 4 C.F.R. §11 .81

(a) Your name and mailing address and, if you wish, other contact information such as a fax number, telep hone number, or e

- mail address:

Re: Exemption Request Total Service Telecom, Inc. Anthony Waver

531 Bonnie Lane

Elk G rove Village, IL 60007

Phone: 312.37 6.3120

Email: A waver@go tst .com

(b) The specific section or se ctions of 14 C.F.R. from which Petitioner seeks an exemption:

 21

- Subpart H Certification procedures for products and parts, Airworthiness Certificates

 61.113

- Private pilot privileges and limitation: Pilot in commandTotal Service Telecom, Inc. 5 | P a g e

 91.103

- Preflight Actions

 91.105

- Flight crewmembers at stations

 91.109

- Flight instruction; Simulated instrument flight and certain flight tests

 91.119

- Minimum safe altitudes: Gen eral

 91.121

- Altimeter settings

 91.151

- Fuel requirements for flights in Visual Flight Rules (VFR) conditions

 91.203

- Civil aircraft: certification required

 91.405

- Maintenance required

 91.407

- Operation after maintenance, preventative maintenance, rebuilding, and alteration

 91.409

- Inspections

 91.417

- Maintenance records

( c) The extent of relief Petitioner seeks, and the reason Petitioner seeks the relief :

P etitioner seeks exempti on from 14 C.F.R. 21, Subpart H, which states the certification procedures for products and parts as well as airworthiness certificates. D ue to the limited airspace P etitioner will be using at cellular locations, Petitioner requests exemption to the airworthiness certification process.

P etitioner has developed training procedures and regulations to promote and provide safe flying experiences for its Pilot in Command (“PIC”)

, which can be viewed in the “Ope rating Pro c edu res”

section of this petition.

P etitioner seeks exemption from 14 C.F.R. 61.113, which discusses private pilot privileges and

limitations for the Pilot in Command (PIC). Specifically, section 61.113 which states “ (a) Except as provided in paragraphs (b) through (h) o f this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircra ft. (b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only in incidental to that business or employment; and (2) The aircraft does not carry passeng ers or property for compensation or hire (c) A private pilot may not pay less than the pro rata share of the operating expenses of a flight with passengers, provided the expenses involved only fuel, oil, airport expenditures, or rental fees. (d) A private pilot may act as pilot in command of a charitable, nonprofit, or community event flight described in §91.146, if the sponsor and pilot comply with the requirements of §91.146. (e) A private pilot may be reimbursed for aircraft operating expenses

that are d irectly related to search and location operations, provided the expenses involve only fuel, oil, airport expenditures, or rental fees, and the operation is sanctioned and under the direction and control of: (1) A local state, or Federal agency; or (2) An o rganization that conducts search and location operations. (f) A private pilot who is an aircraft salesman and who has at least 200 hours of logged flight time may demonstrate an aircraft inflight to a prospective buyer. (g) A private pilot who meets the

re quirements of §61.69 may act as a pilot in command of an aircraft towing a glider or unpowered ultralight vehicle. (h) A private pilot may act as pilot in command for the purpose of conducting a production flight test in a light

– sport aircraft intended f or certification in the light

– sport category under §21.190 of this chapter, provided that

– (1) The aircraft is a powered parachute or a weight

- shift

control aircraft; (2) The person has at least 100 hours of pilot

- in

- command time in the category and cla ss of aircraft flown; and (3) The person is familiar with the processes and procedures applicable to the conduct of production flight testing, to include operations conducted under a special flight permit and any associated operating limitations". P etitioner seeks ex emption from this regulation because there is inconclusive evidence a person with a private pilot certificate can successfull y maneuver a UAS without

first

- hand flight experience with the particular UAS. P etitioner’s own flight training w ith the UAS , as well as adherence to the operating manual provided by the manufacturer, will be more than satisfactory in resolving this issue

.Total Service Telecom, Inc. 6 | P a g e

P etitioner seeks exemption from14 C.F.R. 91.103, which discusses pre

- flight actions. Specifically, section

91.1 03, which states "Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include: (a) For a flight under IFR or a flight not in the vicinity of an airport, weathe r reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and any known traffic delays of which the pilot in command has been advised by ATC; (b) For any flight, runway lengths at airports of intended use , and the following takeoff and landing distance information: (1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therei n; and (2) For civil aircraft other than those specified in paragraph (b) (l) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gr oss weight, and wind and temperature" . An exemption is requested from section 91.103, as FAA approved rotorcraft flight manuals will not be used. In the absence of the flight manuals, the PIC will take all pre

- flight actions, including reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft performance data before starting a flight.

Petitioner seeks exemption from 14 C.F.R. 91.105, which discusses f light c rewmembers at stations. Specifically, 91.105, which states "(a) During takeoff and landing, and while en

- route, each required flight crewmember shall (1) Be at the crewmember station unless the absence is necessary to perform

duties in connection w ith the operation of the aircraft or in connection with physiological needs; and (2) Keep the safety belt fastened while at the crewmember station. (b) Each required flight crewmember of a

U.S.

- registered civil aircraft shall, during takeoff and landing, k eep his or her shoulder harness fastened while at his or her assigned duty station. This paragraph does not apply if (1) The seat at the crewmember's station is not equipped with a shoulder harness; or (2) The crewmember would be unable to perform required duties with the shoulder harness fastened”. P etitioner seeks exemption from this regulation due to the fa ct that the UAS will not have a flight crew or crew station other than the PIC and

VO

. Additionally, t he PIC and VO will not be restrained into a seat via shoulder harness or safety belt at the time of the flight.

Petitioner seeks exemption from 14 C.F.R. 91.109, which discusses flight instruction, simulated instrument flight, and certain flight test s. Specifica lly, 91.109, which states

, "(a) 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. However, instrument flight instruction may be given in an airplane that is equipped with a sing le, functioning throw over control wheel that controls the elevator and ailerons, in place of fixed, dual controls, when (1) The instructor has determined that the flight can be conducted safely; and (2) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings. (b) An airplane equipped with a single, functioning throw over control wheel that controls the elevator and ailerons, in place of fixed, dual controls may be used for flight instruction to conduct a flight review required by §61.56 of this chapter, or to obtain recent flight experience or an instrument proficiency check required by §61.57 when (1) The airplane is equipped with operable rudder pedals at both pilot stations; (2) The pilot manipulating the controls is qualified to serve and serves as pilot in command during the entire flight; 3) The instructor is current and qualified to serve as pilot in command of the airplane, meets the requirements of §61.195(b), and has logged at least 25 hours of pilot

- in

- command flight time in the make and model of airplane; and (4) The pilot in command and the instructor have determined the flight can be conducted safely. (c) No person may operate a civil aircraft in simulated instrument flight unles s (1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown. (2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent observer in the aircraft adequately supplements the vision of the safety pilot; and (3) Except in the case of lighter

- than

- air aircraft, that aircraft is equipped with fully functioning dual controls.Total Service Telecom, Inc. 7 | P a g e

However, simulated instrument flight may be conducted in a single

- engine airplane, equipped with a single, functioning, throw over control wheel, in place of fixed, dual controls of the elevator and ailerons, when (i) The safety pilot has determined that the flight can be conducted saf ely; and (ii) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings. (d) No person may operate a civil aircraft that is being used for a flight test for an airline transport pilot certific ate or a class or type rating on that certificate, or for a part 121 proficiency flight test, unless the pilot seated at the controls, other than the pilot being checked, is fully qualified to act as pilot in command of the aircraft". Petitioner asserts th ere is inconclusive evidence a person with a private pilot certificate or license can successfully maneuver or train someo ne to use a UAS without first

- hand flight experience with the particular UAS. Therefore, petitioner believe s its own flight training a nd first

hand experiences with the UAS will be satisfactory. In addition , the UAS will be operated by a remote control, which will onl y require a one

- person operator; dual controls will not be necessary.

P etitioner seeks exemption from 14 C.F.R. 91.119, which discusses minimum safe altitudes. Specifically, 14 C.F.R. 91.119, which states "Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (a) anywhere

. An al titude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. (b) Over congested

areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons,

an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the airc raft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. (d) Helicopters, powered parachutes, and weight

- shift

- control aircraft . If the operation is conducted without hazard to persons or property on the surface

- (1) A

he licopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and (2) A powered parachute or weight

- shift

- control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section". P etitioner seeks exemption from this regulation due to the fact towers are less than 400ft and flights will be in close

prox imities to towers in order to gather information.

P etitioner seeks exemption from 14 C.F.R. 91.121, which discusses altimeter settings. Specifically, 14 C.F.R. 91.121, (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

– (1) Below 18,000 feet MSL, to

– (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (i i) If there is no station within the area prescribed in paragraph (a) (1) (i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the d eparture airport or an appropriate altimeter setting available before departure; or (2) At or above 18,000 feet MSL, to 29.92 Hg. (b) The lowest usable flight level is determined by the atmospheric pressure in the area of operation as shown in the followin g table:

Current Altimeter S etting Lowest U s eable Flight L evel 29.92 (or higher} 180 29.91 through 29.42 185 29.41through 28.92 190 28.91 through 28.42 195 28.41 through 27.92 200 27.91through 27.42 205 27.41 through 26.92 210Total Service Telecom, Inc. 8 | P a g e

(c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum flight level, the pilot shall take the flight level equivalent of the minimum altitude in feet and add the appropriate number of feet specified below, according to the current reported altimeter setting:"

Current Altimeter S etting Adjustment F actor 29.92 (or higher} None 29.91 through 29.42 500 29.41through 28.92 1,000 28.91 through 28.42 1,500 28.41 through 27.92 2,000 27.91 through 27.42 2,500 27.41 through 26.92 3,000

P etitioner ’s UAS does not have a barometric altimeter, but instead outputs GPS altitude data, which warrants a request for exemption . An equivalent level of safety can be achieved by the PIC confirming the altitude of the launch site shown on the GPS altitude indicator before and during the flight.

P etitioner seeks exemption from 14 C.F.R. 91. 151, which discusses fuel requirements for flight in VFR conditions. Specifi cally, 91.151 which states

, "(a) No person may begin 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 spe ed

- (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. (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions)

t here is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes". P etitioner’s UAS has a maximum flight time of 25 minutes

, which

is less than the 30 minute reserve minimum. This reserve minimum would not even allow P etitioner ’s

UAS a chance to fly. P etitioner ’s aircraft flight manual instructs the PIC to maintain flight until battery power reaches 25 percent

. P etitioner belie ves the restraint issued in its aircraft flight manual achieves a satisfactory safety standard. This restriction would be more than adequate to return the UAS to its home

point or pre

- determined landing

- zone from anywhere in its already limited operating a rea. Petitioner’s UAS will not be flown during night or late evening hours.

P etitioner seeks exemption from 14 C.F.R. 91.203, which discusses civil aircraft required certi fications. Specifically, 91.203, which states

, "(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. Each U.S. airworthiness certificate used to comply with this subparagraph (except a special fli ght permit, a copy of the applicable operations specifications issued under §21.197(c) of this chapter, appropriate sections of the air carrier manual required by parts 121and 135 of this chapter containing that portion of the operations specifications iss ued under §21.197(c), or an authorization under §91.611) must have on it the registration number assigned to the aircraft under part 47 of this chapter. However, the airworthiness certificate need not have on it an assigned special identification number be fore 10 days after that number is first affixed to the aircraft. A revised airworthiness certificate having on it an assigned special identification number that has been affixed to an aircraft may only be obtained upon application to an FAA Flight Standard

s district office. (2) An effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft registration Application as provided for in §47.31{c), or a registration certification issued under the laws of a foreign country. (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

entra nce so that it is legible to passengers or crew. (c) No person may operate an aircraft with a fuel tank installed within the passenger compartment or a baggage compartment unless the installation wasTotal Service Telecom, Inc. 9 | P a g e

accomplished pursuant to part 43 of this chapter, and a copy of FAA Form 337 authorizing that installation is on board the aircraft. (d) No person may operate a civil airplane (domestic or foreign) into or out of an airport in the United States unless it complies with the fuel venting and exhaust emissions

requ irements of part 34 of this chapter". P etitioner believes an appropriate and current airworthiness

certificate is not necessary to fly a UAS given the size of the aircraft and the necessary level of skill needed to operate the aircraft. Petitioner seeks ex emption from this regulation because the rule is not

meant for a UAS or its operators.

P etitioner seeks exemption from 14 C.F.R. 91.405, 91.407, 91.409, and 91.417, which discusses required aircraft maintenance, operation after maintenance, preventive maintenance, rebuilding, or alteration, inspections, and maintenance records. In P etitioner ’s aircraft flight manual, maintenance and inspection procedures have been established for the aircraft. P etitioner believes these regulations are meant for manned operated aircrafts and not unmanned systems, therefore making them unnecessary. P etitioner seeks an exemption from any such specific provisions to the extent FAA finds it necessary to grant this
request.

(d ) The reasons why granting Total Service Telecom's request would be in the public interest; that is, how it would benefit the public as a whole :

P etitioner provides services to the wireless and electrical industry. Wireless services have become a major

ba ckbone for nationwide 911 emergency response and digital infrastructure. Petitioner ’s use of a UAS

will assist in verifying the components that make up that backbone are fully functional and in proper repair. Petitioner ’s UAS usage in the wireless industry will enable it to gather valuable information to

increase p roductivity and more importantly improve safety. T he UAS will minimize the need for

technicians to climb cell towers, putting fewer lives in danger. Ultimately, climbers will still be required

to install tower equipment, but a UAS will decrease the amount of times a climber is needed. G rantin g the exemption will not adversely affect safety, and Petitioner warrants it will provide a level of safety that exceeds current safety requirements dictated by the FAA for its use of a UAS.

( e ) A summary FAA can publish in the FEDERAL REGISTER, stating: (1) The rule from which you seek the exemption; and (2) A brief description of the n ature of the exemption you seek:

Petitioner : Total Service Telecom, Inc. Sections of 14 C.F.R. Affected: 21Subpart H; 61.113(a)(b); 91.103; 91.105; 91.109; 91.119(c); 91.121(a)(l)(iii); 91.151(a)(l); 91.203; 91.405; 91.407; 91.409; and 91.417

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. 21 Subpart H; 61.113(a)(b); 91.103; 91.105; 91.109; 91.119(c); 91.121(a)(1)(iii); 91.151(a)(1);91.203; 91.405; 91.407; 91.409; and 91.417 to conduct telecommunications and utility structure inspection, construction, and

maintenance services

. Flights will occur on customer property and will be subject to operating procedures that meet or exceed those that FAA requires.

(f) An y additional information, views, or arguments av ailable to support your request:

 Please see the introduction to this exem ption request.

( g ) If you want to exercise the privileges of your exemption outside of the United States, the reason why you need to do so:

 The Operations described in this exemption request will be conducted wholly within the United

States.Total Service Telecom, Inc. 10 | P a g e

Please do not hesitate to contact me via email at a waver@go tst .com or by phone if you have any question

or concerns.

Respectfully submitted,

Anthony Waver Total Service Telecom, Inc

. 312.376.3120 ext. 802