T & N Professional Services LLC

dba Precision Property Inspections

30 Wingspan Drive

Spring, TX 77381

t imou@comcast.net

832

- 515

- 4646

June 10, 2015

US D epartment Of Transportation

Federal Aviation Administration

800 Independence Ave SW T & N Professional Services, LLC

Washington DC 20591

Dear Sir or M adam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012(the reform act) and CFR Pa rt 11, T & N Professional Services LLC , dba Precision Property Inspections , owner and operator of Small Unmanned Aircraft Systems (UASs), request to be exempted from the F ederal Aviation Regulations (FAR)

listed below so that T & N Professional Services LLC may operate UASs commercially in airspace regulated by the FAA., as long as suc h operations are

conducted with in and under the conditions outlined herein or as maybe established by t he FAA as required by Section 333.

T & N Professional Services LLC is co

- owned by Thomas (Tim ) Gregory and Nancy Gregory

. Both have Texas Drivers licenses. Mr. Gregory has a private pi lot’s licens e and will be the PIC. All operations will be performed with the public’s safety and right to privacy safe guarded at all times.

As described below, the requested exception would permit the operation of light weight (less than 55 lbs . total takeoff weight) UASs under controlled conditions

for c ommercial use by a certified private pilot thereby enhancing safety and fulfilling the Secretary of Transportation’s ( the FAA Administrator’s) responsibility to” establish requirements for saf e operation of such aircraft systems in national airspace systems.” Section 333(c) , o f the Reform Act.T & N Professional Services LLC UAS is a rotorcraft weighing less than 55

pounds including payload. ( Th e DJI Phantom 3 Quad Copter ) It operate s at a

s peed less than 50 knots and has the capability to hover and move in the vertical and horizontal plane simultaneously. It has an auto return mode th at can be

activated from remote control or is automatic when battery power is under 25%, if signal is lost between remote control and UAS or multiple GPS signal s are lost

. The UAS will operate withi n the line of sight with in a protected flight area as

described be low and at 200 feet AGL or less with an observer located close at hand as to make voice communication possible. These operations will not create a hazard to users of the nation airspace, pu blic nor the environment.

T & N Professional Services LLC respectfully requests the grant of an exception to the following specific sections of the Title 14 Code of Federal regulations allowing it to operate lightweight UASs for commercial use,

14 CFR 21, subpart H, 14 CFR 45.23 (b) 14 CFR 91.7 (a), 91.9 (b) (2) 91.103 (b) , 91.109, 91.119, 91.121,91.151,(a), 91.203(a) &(b),91.405(a),91.407(a)(1), 91.409(a)&(b).

T & N Professional Services LLC submits this application in accordance with the Reform Act ,112 P.L. 95 3 31

- 334, seeking relief from any currently applicable FAR’S operating to prevent T & N Professional Services LLC future commercial

use of small UASs to operate in the national airspace system as described below. The reform Act section 332 provides for such integration of civil unmanned aircraft into our national airspace system as it is in the public’s interest

to do so. T & N Professional Services LLC UAS meet s the definition of “small unmanned aircraft” as defined in Section 331 and therefor the integration of these UASs are expr essly contemplated by the Reform Act. T & N Professional

Services LLC would like to operate its light weight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such

aircraft.

The Reform Act directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in national airspace

before completion of the rule making required under Section 332 of the reform Act. In making this determination, the Secretary of Transportation is required to determine which UASs do create a hazard to users of the national airspace system or the public or pose a threat to national security in light of the following:

The UASs size, speed, weight and operational capability

Operation of t he UASs in close proximity to airports and populated areas

Operation of the UASs within visual line of sight of the operator

Reform Act 333(a). If the secretary determines that such vehicles “may operate safely in National Airspace System, the s ecretary shall establish requirements for the safe operation in national airspace.T & N Professional Services LLC will operate rotorcraft weighing less than 55 lbs.

an d operate at speeds less than 50 knots and have the capability to operate in

the vertical and horiz ontal plane simultaneously. The UAS will operate only

within the lin e of sight of the operator with in a protected flight area and at 200

feet AGL or less. These will not present a hazard to the national airspace nor the public.

The very small nature o f these UASs combined with the safe guards presented below, will allow for the safe operation greater than that envisioned by Congress for the FAA to establish and by exemption allow commercial operations of UASs to commence immediately. Also due to the si ze of UASs and the areas and altitudes they will operate approval of this exception presents no national security issues and absolutely minimal safety concerns which have been mitigated through our rigorous risk management process. Given the clear directio n given in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the strong equivalent level of enhanced safety, reduced emissions utilizing UASs verse s traditional aircraft as well a s the economic impact of greatl y reducing the cost of aerial photography thereby benefiting the greater public’s interest. Accordingly, the applicant requests that the FAA grant the requested exemption without delay.

The following will be considered as the binding limitation on operations of T & N

Professional Services LLC.

1. Flights will only occur in the day time hours,

2. Flights will be operated in th e line of sight of the operator ( PIC ) and Observer, (VSO)

3. Flights will be te rminated at any time weather and wind deteriorate to “unsafe for flight” by manufacturers recommendations,

4. The UAS will weigh less that 55 lbs.,

5. Flights will be operated at 200 feet AGL or less.

6. Crew w ill be at a minimum of operator (PIC) and an observer and/or camera
operator (VSO)

, 7. Operator and crew will remain in contact during the flight operation,

8. The UAS operator will perform a check of the flight area and make certain of the safety of all persons in the area,

9. Consent will be obtained from all persons with in the video capabilities of the units to further reduce the chance of violating anyone’s privacy.

10. All required FAA clearances, will be obtained and distances from airports strictly observed.

11. All UAS will have the capability to return automatically to the operator in a safe manner with the auto return function checked and working.

12. Flights will only operate in VFR conditions.

13. UAS has a function on the control to tell operator the distance away from the operator and its battery power remaining.

14. Flight team will communicate by voice and the use of two

- way radio if the area is too big to hear voice from all team members.15. When operating over or near a body of water the UAS will be equipped with

flotation devices so that recovery can be made as to prevent lithium battery exposure to the water table.

14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7(a), 91.203(a)(1)

Subpart H, entitled A irworthiness Certificates, sets forth requirements for procurement of necessary certificates in relation to FAR 91.203(a)(1). The size, weight and defined area of operations for T & N Professional Services LLC UAS flights permits exception from Part 21 because they me et an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 USC 4470(f) and Section 333 of the Reform Act. Both pieces of legisla tion permit the FAA to exempt UASs from airworthiness certificates in consideration of weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. T & N Professional Services LLC meets or exceeds each

of these elements

As of Marc h 23, 2015 the FAA has stated that it will automatically grant a

“blanket” COA for flights at or under 200 AGL to any UASs operator with a section 333 exemption.

14 CFR 91.203(a&b) provides for carrying of civil aircraft certifications and registrati ons. These are inapplicable for the same reasons stated above. Any certifications and registration information will be maintained at the corporate

address.

14CFR91.7 (a) prohibits the operation of an ai rcraft without an airworthiness

certificate. As no such certificate will be applicable in the form contemplated by FAR’s this regulation is inapplicable.

14 CFR 91.9(b)(2) requires an aircraft flight manual in the aircraft. A s there are no pilots or passengers , and given the size of the UAS this regulation is inapplicable

The FAA has previously issued exemptions to this regulation in Exemptions No’s 8607,8737,8738,9299,9299A,9565,9565B,10167,10167A,10602,10700 and

32827.

14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operatio n of civil aircraft. It allows helicopters to be operated at lower altitudes in certain

conditions. T & N Professional Services LLC will only operate its UAS at or below

200AGL. It will be operated on a will defined AOR that has been carefully

reviewed for hazards and minimizes the presence of any persons not essential for these operations. Flights will only be over private property that the owner has consented and all persons with in this video area also give consent for this filming. Compared to flight operations o f conventional and traditional aircraft or rotorcraftweighing far more than 50 lbs. , operating below 500 AGL with flammable fuel

UASs operations present a far smaller risk to the public.

Approval of these 333 Exemption s allowing commercial operations of small UASs in the service of aerial photography will greatly enhance safety by reducing the

overall risk associated with traditional aircraft. Traditional aerial photography requires large aircraft with flammable fuel to fly in close proximity of populated areas and people in general. With the use of sma ll UASs of 55 lbs. or less, battery operated and fling below 200 feet AGL the risk of injury of people on the ground or the crew has been reduced or almost erased. The gran tin g of the use of these

small UAS by T & N Professional Servic es LLC will give the people and business another avenue to express themselves and to have a video record to share with clients, family and or friends.

Granting T & N Professional Services LLC the above exemption will allow for the

expa nsion of UAS systems into the future for the safe conduct of free enterprise and the enjoyment of the masses.

T & N Professional Services LLC , dba Precision Property Inspections, respectfully requests the FAA grant its exception without delay. The FAA has the authority to issue the exemption sought by T & N Professional Services LLC pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as amended (the ACT).

Sincerely

, 

# 

T homas (Tim) Gregory

T & N Professional Services LLC

30 Wingspan D rive

Spring, TX 77381

timou@comcast.net