531 Bonnie Lane, Elk Grove Village, IL 60007 * 312.376.3120 * www.gotst.com

Total Service Telecom, Inc. 1 | P a g e

December 14

th, 2015

U.S. Department of Transportation (DOT) 

Unmanned Aircraft Systems 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 submits 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 inspection, 

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 telecommunications 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 possible “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 

Petitioners customers and property owners.

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

involves 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 malfunctioning 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 worker 

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 involves 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 the project, and those subcontractors may 
Total 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 actually perform the work (or certain parts of the work). This business structure poses challenges to 

setting and enforcing safety rules and ensuring the well-being of employees, and gives companies like cell 

carriers a powerful incentive to avoid any role in worker safety.

A search of OSHA's Integrated Management Information System (IMIS) database for both fatal and nonfatal incidents involving communication towers revealed 107 incidents from 2003 through 2013 (Docket 

ID OSHA-2014-0018-01). These incidents resulted 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 while 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 include all incidents that 

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 current 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 scope 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 

by 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. Lightning 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 flying 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 currently 

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 accurate 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. Although 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 possible 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 aircrafts 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 Person 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 

operational 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 structures.

 All flights will 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 will 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 including 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 surfaces 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 during 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 hours 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 when 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 safety 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, any 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, the 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 immediately 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 regained 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 recalibrated 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 the “ready to fly” status.

 The 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, 

telephone number, or e-mail address:

Re: Exemption Request 

Total Service Telecom, Inc.

Anthony Waver

531 Bonnie Lane

Elk Grove Village, IL 60007

Phone: 312.376.3120 

Email: Awaver@gotst.com

(b) The specific section or sections 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 command 
Total 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: General 

 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:

Petitioner seeks exemption from 14 C.F.R. 21, Subpart H, which states the certification procedures for 

products and parts as well as airworthiness certificates. Due to the limited airspace Petitioner will be 

using at cellular locations, Petitioner requests exemption to the airworthiness certification process. 

Petitioner 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 “Operating Procedures” 

section of this petition.

Petitioner 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) of this section, no person who holds a private pilot certificate may 

act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; 

nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot 

may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or 

employment if: (1) The flight is only in incidental to that business or employment; and (2) The aircraft 

does not carry passengers 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 directly 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 organization 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 

requirements 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 for certification in the light – sport category 

under §21.190 of this chapter, provided that – (1) The aircraft is a powered parachute or a weight-shiftcontrol aircraft; (2) The person has at least 100 hours of pilot-in-command time in the category and class 

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". Petitioner seeks exemption from this regulation because there is 

inconclusive evidence a person with a private pilot certificate can successfully maneuver a UAS without 

first-hand flight experience with the particular UAS. Petitioner’s own flight training with 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

Petitioner seeks exemption from14 C.F.R. 91.103, which discusses pre-flight actions. Specifically, section 

91.103, 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, weather 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 therein; 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 gross 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 flight crewmembers 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 with 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, keep 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”. Petitioner seeks exemption from this 

regulation due to the fact that the UAS will not have a flight crew or crew station other than the PIC and 

VO. Additionally, the 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 tests. Specifically, 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 single, 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 unless (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 safely; 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 certificate 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 there is inconclusive evidence a person with a private 

pilot certificate or license can successfully maneuver or train someone to use a UAS without first-hand 

flight experience with the particular UAS. Therefore, petitioner believes its own flight training and firsthand experiences with the UAS will be satisfactory. In addition, the UAS will be operated by a remote 

control, which will only require a one-person operator; dual controls will not be necessary.

Petitioner 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 altitude 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 aircraft 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 

helicopter 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". Petitioner seeks 

exemption from this regulation due to the fact towers are less than 400ft and flights will be in close 

proximities to towers in order to gather information.

Petitioner 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; (ii) 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 departure 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 following table:

Current Altimeter Setting Lowest Useable Flight Level 

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 26.92 210 
Total 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 Setting Adjustment Factor 

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 

Petitioner’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.

Petitioner seeks exemption from 14 C.F.R. 91. 151, which discusses fuel requirements for flight in VFR 

conditions. Specifically, 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 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. (b) No person may begin a 

flight in a rotorcraft 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, to 

fly after that for at least 20 minutes". Petitioner’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 Petitioner’s

UAS a chance to fly. Petitioner’s aircraft flight manual instructs the PIC to maintain flight until battery 

power reaches 25 percent. Petitioner believes 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 homepoint or pre-determined landing-zone from anywhere in its already limited operating area. Petitioner’s 

UAS will not be flown during night or late evening hours.

Petitioner seeks exemption from 14 C.F.R. 91.203, which discusses civil aircraft required certifications. 

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 flight 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 issued 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 before 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 Standards 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 

entrance 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 was 
Total 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 

requirements of part 34 of this chapter". Petitioner 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 exemption from this regulation because the rule is not 

meant for a UAS or its operators.

Petitioner 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 Petitioner’s aircraft flight manual, maintenance and inspection 

procedures have been established for the aircraft. Petitioner believes these regulations are meant for 

manned operated aircrafts and not unmanned systems, therefore making them unnecessary. Petitioner

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:

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

backbone 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 productivity and more importantly improve safety. The 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. Granting 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 nature 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) Any additional information, views, or arguments available to support your request:

 Please see the introduction to this exemption 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 awaver@gotst.com or by phone if you have any question 

or concerns. 

Respectfully submitted,

Anthony Waver

Total Service Telecom, Inc.

312.376.3120 ext. 802