Attention: 

U.S. Department of Transportation Docket Operations

West Building Ground Floor, Room w-12-140

1200 New Jersey Ave, SE Washington, D.C. 20590

RE: TC Aerial Media LLC Requests an Exemption From the Requirements of Title 14 of the 

Code of Federal Regulations

part 21, sub. H, Section 91.7(a), Sections 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) 

and (b), Section 91.9(b)(2), Section 91.119, Section 91.121, Section 91.151(a), Section 61.3, and 

Section 45.23

TC Aerial Media LLC

Travis Ruthig

13044 Vernon Ave. 

Savage, MN 55378

tcaerialmedia@gmail.com

952-200-8803
PETITION FOR EXEMPTION FROM 14 CFR 

I. Introduction

TC Aerial Media LLC (“TC Aerial”) seeks exemption from the requirements of 14 CFR 

part 21, sub. H, Section 91.7(a), Sections 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) 

and (b), Section 91.9(b)(2), Section 91.119, Section 91.121, Section 91.151(a), Section 61.3, and 

Section 45.23, to operate an Unmanned Aircraft System (“UAS”) pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012 for Aviation Unmanned to perform aerial 

photography and videography by/for Travis Ruthig, owner of TC Aerial Media LLC. This 

exemption will permit TC Aerial to operate a UAS for the commercial purpose of conducting 

aerial video and photography.

The requested exemption would support an application for a commercial Certificate of 

Authorization to use the below-described UAS to support production of promotional materials 

(video and/or still images) for real estate sales, travel and tourism industries, commercial 

businesses, and for photography and videography of social events, such as weddings. The UAS 

will not operate over persons not directly involved with the UAS.

II. TC Aerial’s UAS

TC Aerial seeks an exemption to operate a UAS manufactured by DJI called the DJI 

Inspire 1. The DJI Inspire 1 user manual is available to download or view here: 

http://www.dji.com/product/inspire-1/download. TC Aerial will ensure that the UAS is 

maintained and in safe operational condition at all times. 

This UAS weights approximately 6.5 pounds, has a maximum speed of about 45 mph, 

and a diagonal distance between two propellers of about 22 inches. The radio frequency used to 

communicate between the radio controller (“RC”) and the UAS craft will always be 2.4GHz.

The UAS has the following specifications: 

- A lightweight (approximately 6.5 lbs. with all onboard equipment) craft manufactured by

DJI –The Inspire 1 that contains all of the following equipment in flight;

o An on-board flight computer with GPS navigation and location ability that 

receives signals for flight controls from a ground-based transmitter/controller;

o An on-board camera capable of capturing imagery in the form of full color, high 

definition still photos and video;

o An on-board telemetry system that delivers flight data from the on-board flight 

computer to the on-board radio transmitter including altitude AGL, horizontal and 

vertical speed, compass direction of flight and direction back to its launch site;

and
o A 2.4GHz on-board radio transmitter that transmits live video from the on-board 

camera plus all the flight data from the telemetry system described above.

- The ground station-based part of the UAS has the following specifications:

o A Pilot in Command (PIC) in operational control of a flight operation from 

beginning to end and who controls the UAS while in the air; occasionally a 

second operator that would be just controlling the camera of the UAS; 

o A 2.4GHz radio transmitter/controller operated by the PIC to control the UAS

while in flight; A radio receiver receiving live video and flight data from the onboard camera and computer projects it all together onto a screen for the PIC to 

view during flight;

o A Visual Observer (VO) is a person who provides a second pair of eyes to 

visually track the UA while in flight; and

o A spotter can operate the camera from a second RC, although their controller only

communicates with the PIC’s controller at 5.8GHz with no access to the flight 

controls – only camera controls.

III. TC Aerial’s PIC

TC Aerial has over 100 hours of flight on various UAS’s without incident. TC Aerial has

built its own UAS’s from the ground up and has spent extensive time learning and perfecting 

UAS flight. Specifically, with the DJI Inspire 1, TC Aerial has over 20 hours of flight – again 

without incident. TC Aerial has no liens or judgments against it, and no arrests or felonies. 

IV. TC Aerial’s Intended Operations

TC Aerial will operate its UAS to produce promotional materials (video and/or still

images) for real estate sales, travel and tourism industries, commercial businesses, and for 

photography and videography of social events, such as weddings. 

The safe operation to the National Air Space (“NAS”), persons, and/or property will be 

ensured by always flying the UAS within line-of-sight. Visual contact with the UAS will be 

maintained at all times for the duration of the flight. The safety of the NAS, operators, and the 

public will also be ensured by never flying the UAS over 400 feet above ground-level. The UAS 

will also never be flown directly above persons or within five miles of any airport. A spotter will 

be used during flights to help assist maintaining flight safety. 

To assist in the safe operation of the UAS, the PIC will always have a visual of the 

battery life through the DJIGO flight application. Operation will always come to a halt once 

battery life reaches 30% life – ensuring that there will never be a battery failure during flight. 

This application also has built in maximum altitude settings, which will never be higher than 400 

feet AGL. The DJI Inspire 1 also has the following safety features: return to home button and 

transmitter lost signal – return to home. 

Pre-flight inspections of the UAS will always include checking all batteries for condition 

in the UAS craft as well as the RC. In addition, the drone no fly zone map will be checked before 

any and all flights (https://www.mapbox.com/drone/no-fly/) because no flights will ever occur 
inside of a no-fly zone. Also, the device battery that runs the flight application (DJIGO) will also

be checked and charged. Firmware of the smart batteries, the RC, and the UAS craft will always 

be up to date. The flight application will also always be the latest version. The propellers will 

always be inspected for nicks or cracks and before take-off will be secured and locked to the 

propeller motors. 

Flight area conditions will always be checked – clear of obstacles/tress, no persons 

nearby or in the flight path, no power lines or other obstacles overhead, and wind gusts less than 

18 mph. Wind speeds and gusts greatly affect the small UAS and will always be factored in for 

safe flying. A flight log of all future flights will be kept to keep track of all operations. This will 

include time, date, location, and other notable conditions or occurrences during flight.

V. The Public Will Benefit from the UAS

The UAS, powered by batteries, is smaller, lighter and more maneuverable than larger 

aircraft running on combustible fuel, it operates at lower altitudes with no people on board and 

will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of 

death or serious bodily injury. With a small payload and maximum flight time of only 18 

minutes, this offers little or no risk to national security.

Low level oblique photos and video from several angles are far more effective than 

ground based imagery for displaying the characteristics of large, complex properties with several 

buildings and large trees. The alternative could be to charter a full-sized helicopter for this 

purpose, which has proven more costly than many potential clients are able to afford. The 

benefits of reduced cost and improved quality of presentation from the UAS will be valuable to 

and benefit many buyers and sellers of any real estate properties.

The exemption requested by TC Aerial will greatly assist the general public in that this 

type of photography/videography would be beneficial to the consumers (giving them a better 

understanding of the product they may be consuming) and the market professionals (allowing 

them to showcase their product from another perspective). Given the small size of the UAS 

involved and the procedures outlined above, its proposed operation poses no additional public 

safety concerns and thus the FAA, by exemption, should allow commercial operations of this 

UAS. Also due to the size of the UAS and the restricted areas in which the UAS will operate, 

approval of the application presents no national security issue. Given the clear direction in 

Section 333, the strong equivalent level of safety surrounding the proposed operations and the 

significant public benefit, including enhanced safety, reduction in environmental impacts, and 

including reduced emissions associated with allowing UAS for commercial use, granting the 

requested exemptions are in the public interest.

VI. TC Aerial’s Requested Exemptions

Given the operations, technical specifications, and safety precautions described above, 

TC Aerial request exemptions from the following requirements of 14 CFR:
Due to the limited size, weight, speed, and operating area associated with TC Aerial’s 

UAS, an exemption from 14 CFR part 21, sub. H (Airworthiness Certificates) and §91.203(a) 

and (b) (Certifications required), subject to certain conditions and limitations, is warranted and 

meets the requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of 

P.L. 112-95 (Section 333).

TC Aerial requests an exemption from Section 91.7(a) (Civil aircraft airworthiness) 

because TC Aerial’s UAS does not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. Therefore, TC Aerial will ensure that the UAS is in airworthy

condition based upon its compliance with the operating documents (prior to every flight, and 

further, determine that the UAS is in condition for safe flight, as stated in the conditions and 

limitations below.

TC Aerial requests an exemption from Sections 91.405(a), 91.407(a)(1), 91.409(a)(2) and 

91.417(a) and (b) (Maintenance inspections) because these requirements only apply to aircraft 

with an airworthiness certificate. However, as a safety precaution TC Aerial will perform a 

preflight inspection of the UAS before each flight as outlined in the attached operating 

documents.

TC Aerial requests an exemption from Section 91.9(b)(2) which requires an aircraft flight 

manual in the aircraft. Because there are no pilots or passengers on board the aircraft and given 

its size, this regulation is inapplicable. An equivalent level of safety will be achieved by 

maintaining a safety/flight manual with the UAS ground station.

TC Aerial requests an exemption from Section 91.119, which prescribes safe altitudes for 

the operation of civil aircraft. TC Aerial will not operate its UAS above the altitude of 400 feet 

above ground level and will also only operate in safe areas away from the public and traffic, thus 

“providing a level of safety at least equivalent to or below those in relation to minimum safe 

altitudes.” Given the size, weight, maneuverability, and speed of the UAS, an equivalent or 

higher level of safety will be achieved.

TC Aerial requests an exemption from Section 91.121 (Altimeter settings) because it is 

inapplicable. TC Aerial’s UAS utilizes the on-board altimeter telemetry that is relayed to the PIC 

through the DJIGO application. Also, the maximum flight altitude is set in the DJIGO 

application at 400 feet AGL, so flight above that height is impossible. 

TC Aerial requests an exemption from Section 91.151(a) (Fuel requirements for flight in 

VFR conditions). The UAS is 100% electric and two low battery alerts are issued - per the 

operating documents, the UAS will be landed at the first alert. Also, flights will last a maximum 

of 18 minutes each, and the UAS has an automated function, which results in immediate landing 

when a low battery is detected. The PIC will not begin a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly to the first point of intended landing 

and, assuming normal cruising speed, land the UAS with 30% battery power remaining.

TC Aerial requests an exemption from Section 61.3 to the extent necessary to allow a PIC 

to operate a UAS without a pilot certificate. TC Aerial’s UAS is not a civil aircraft, and thus this 
section does not apply. TC Aerial submits that all flights of the UAS will be incidental to TC 

Aerial’s business and will not carry passengers or property for compensation or hire.

TC Aerial requests an exemption from Section 45.23 (Marking of the aircraft) because 

the UAS will not have a cabin, cockpit or pilot station on which to mark certain words or 

phrases. Further, two-inch lettering is difficult to place on such a small aircraft with dimensions 

smaller than the minimal lettering requirement. 

VII. Summary to Public in the Federal Register

TC Aerial seeks exemption from the requirements of 14 C.F.R. part 21, sub. H, Section 

91.7(a), Sections 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b), Section 91.9(b)(2), 

Section 91.119, Section 91.121, Section 91.151(a), Section 61.3, and Section 45.23. These 

exemptions will permit TC Aerial to commercially operate an Unmanned Aerial System (UAS) 

for the purpose of conducting aerial video and photography over certain areas of the United 

States.

VIII. Summary of TC Aerial’s Exemption Request and Justifications

TC Aerial will comply with all of the following conditions and limitations should this 

exemption be granted. 

1) Operations will be limited to the following aircraft described in the operating 

documents, which is a quad-rotor aircraft weighing 6.5 pounds: DJI Inspire 1 Unmanned Aircraft 

System.

2) The UAS will not be flown at an indicated airspeed exceeding 45 mph.

3) The UAS will be operated at an altitude of no more than 400 feet AGL.

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

5) Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe 

flight. This includes the batteries of all of the components, the firmware of all of the components, 

and functional condition of all of the components. If the inspection reveals a condition that 

affects the safe operation of the UAS, the UAS will not be operated until the necessary

maintenance has been performed and the UAS is found to be in a condition for safe flight. All 

maintenance and alterations will be properly documented in the aircraft records/flight logs.

6) The pre-flight inspection section in the operating documents will account for all 

discrepancies, i.e. inoperable components, items, or equipment, not already covered in the 

relevant sections of the operating documents.

7) The UAS will not operate within any no-fly zones. This will be checked against the 

drone no-fly zone map (https://www.mapbox.com/drone/no-fly/).

8) If a UAS loses communications or loses its GPS signal, it will return to a 

predetermined location (home) within the planned operating area and land.

9) The PIC will not begin a flight unless (considering wind and forecast weather 

conditions) there is enough power to fly at normal cruising speed to the intended landing point 

and land the UAS with 30% battery power remaining.

10) The UAS will not be operated directly overhead of any person/s.
11) All operations will be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission from land 

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

12) The public will benefit from a safety standpoint, an environmental standpoint, and 

from an economic standpoint. 

Travis Ruthig

TC Aerial Media LLC

13044 Vernon Ave. 

Savage, MN 55378

tcaerialmedia@gmail.com

952-200-8803