### Towersource,	Inc.	Petition	for	Exemption	Under	Section	333

Towersource, Inc. is a full

-service telecommunications project management firm that seeks relief from all airworthiness certification requirements under the FAA Modernization and Reform Act of 2012, Public Law 112

-95 FEB. 14, 2012, Section 333. The following petition is	designed	to	meet	the	requirements	of	14	CFR	§	11.81,	as	stated	belowin	bold	type: (a) **Your name**  **and mailing**  **address and,**  **if you**  **wish, other**  **contact information**  **such	as	a	fax	number,	telephone	number,	or	e -** **mail	address**: a. Name:	Marshall	Hazlehurst,	representing	Towersource,	Inc. b. Mailing	Address:	1875	Old	Alabama	Road	Suite	1008; Roswell,	GA	30076 c. Email: nsavage@towersourceinc.com (b) **The specific**  **section or**  **sections of**  **14 CFR**  **from which**  **you seek**  **an exemption** **.** Section	333

. (c) **The extent**  **of relief** **you seek,**  **and the**  **reason you**  **seek the**  **reli ef** 

. Towersource, Inc.	seeks	an	exemption of	Section	333 in	order	to	fly	an	UA	at	flights	lower	than	400 feet	for	commercial	purposes. **(d) The	reasons	why	granting	your	request	would	be	in	the	public	interest;	that	is,**  **how it**  **woul d**  **benefit the**  **public as**  **a whol** **e.** A comprehensive list of the services Towersource’s UA will perform can be found in the section below titled Regarding the Operation of the Unmanned Aircraft , number 6. These services are all in the greater interest of the public. Below, Towersource has highlighted three particular benefits: a. Wildlife Conservation: one of the primary services Towersource will offer with the UA will be inspections forvulnerable or threatened species.	Cellular towers are common nesting places for ospreys, an endangered bird of prey. Using the UA, Towersource can determine if ospreys are nesting, and when work can safely be resumed once their fledglings leave the nest. Without an AU, it is impossible to determine the information, leaving a chance to have the	osprey	go	undiscovered	and	construction	interfere	with	their	nests. b. Decrease in Tower

-Related Fatalities: Since 2008, over 50 tower-related deaths have occurred. With an ever-increasing number of towers and telecom workers, that number will only rise. In order to reduce the fatalities, more tower workers must stay on the ground rather than climb. UAs are the perfect solution to the dangerous profession, as all of the audits and inspections that Towersource will offer with the UA are currently done by climbers. With fewer climbers performing routine audits, fewer lives are risked. c. Increase in Public Access to Wireless Networks: UA deployment allows for quicker, cheaper inspections, which lead to faster issue resolution. If equipment is broken or specifications need to be verified, UAs are much more practical and easier than deploying an entire tower crew. The savings and ease transfer to the end consumer, who can enjoy a more reliable, less expensivewireless	network.(e) **The reasons**  **why granting**  **the exemption**  **would not**  **adversel y**  **affect safety,**  **or**

**how the**  **exemption would**  **provide a**  **level of**  **safety at**  **least equal**  **to that**  **provided by**  **the rule**  **from which**  **you seek**  **the exemption** 

. As stated above, the use of UAs for towers inspections and audits would significantly increase safety from a telecommunications standpoint. From the standpoint of the FAA, Towersource’s use of UAs would not adversely affect safety in any way due to the company’s policies offlight conditions, locations and personnel requirements (all of which	are	detailed	in	numbers	1

-12	below). (f) **A summary**  **we can**  **publish in**  **the Federal**  **Register, stating:**  **t he**  **rule from**  **which you**  **seek the**  **exemption; and**  **a brief**  **description of**  **the nature**  **of the**  **exemption you**  **seek**

. Towersource, Inc. seeks exemption from all airworthiness certification requirements under the FAA Modernization and Reform Act of 2012, Public Law 112

-95 FEB. 14, 2012, Section 333 in order to provide telecommunication	services	in	a	commercial	capacity. (g) **Any additional**  **information, views**  **or arguments**  **available to**  **support yo** **ur request** 
. Please see numbers 1

-12 below for more information, views and arguments. (h) **If you**  **want to**  **exercise the**  **privileges of**  **your exemption**  **outside the**  **United States,**  **the reason**  **why you**  **need to**  **do so** . Towersource does not seek exemption outside	of	the	United	States. The following paragraphs adhere to the format outlined in the “FAA’s Public Guidance for Petitions	for	Exemption	Filed	under	Section	333.” Regarding	the	Unmanned	Aircraft	System **1. Petitioners**  **should describe**  **how the**  **proposed UAS**  **operation will**  **be safely**  **conducted to**  **minimize risk**  **to the**  **NAS or**  **to persons**  **and property**  **on the**  **ground. Specifically,**  **petitioners should**  **describe the**  **design and**  **operational characteristics**  **for the**  **type(s) of**  **UAS they**  **intend to**  **operate, e.g.**  **aircraft performance**  **and performance**  **limitations, operating**  **procedures, and**  **aircraft loading	information	in	as	much	detail	as	possible** **.** a. How operation will minimize risk to NAS/persons/property: Towersource’s UA will be	used	to	inspect	certain	aspects	of	telecommunications	towers.	The UA will be flown over a very small area of land, which will be vacant aside from the PIC and visual observer. No crowds or onlookers will be within the flight	path.	The	property	over	which	the	drone	will	be	flying	will	be	owned	by our clients and will be in no danger of damage. For more on this topic, see numbers	6

-8	below. b. Design and operational characteristics for UAS: Towersource will be using DJI’s Phantom 2 Vision+ UA, a popular model known for its ease of use and leading safety/performance record. For detailed design and operational characteristics and limitations, please see attached user manual. Quick reference	information	is	available	below: i. Weight:	2.7	pounds ii. Maximum	payload:	2.9	poundsiii. Max	flight	speed:	15	m/s	(Towersource	will	not	operate	at	that	speed)

2. **Petitioners should**  **describe any**  **procedures they**  **would implement,**  **such as**  **pre -** **flight inspections,**  **maintenance, and**  **repair, to**  **ensure that**  **the UAS**  **is in**  **a condition**  **for safe**  **flight .**  The Towersource PICs will follow DJI’s recommended policies and procedures in addition to our internal OHSA

-driven best practices. Below	we	have	listed	several	categories	and	the	steps	for	each: a. Preflight	Checklist: i. Remote Controller, smart battery, Range Extender and smartphone are	fully	charged ii. Propellers are	mounted	correctly iii. Gimbal	clamp	has	been	removed iv. Dampening	absorbers	are	in	good	condition,	not	broken	or	worn v. Anti

-drop	kits	have	been	mounted	correctly vi. Camera	lens	cap	has	been	removed vii. Micro

-SD	card	has	been	inserted	if	necessary viii. Gimbal	is	functioning	as	normal ix. Motors	can	start	and	are	functioning	as	normal x. DJI	Vision	App	can	connect	to	the	camera b. Maintenance: regular maintenance will occur per DJI’s suggested maintenance	schedule.	This	includes	weekly,	monthly	and	yearly inspections

. i. All	maintenance	and	repairs	will	be	completed	by	the	manufacturer. 3. **The petitioner**  **should describe**  **the Radio**  **Frequency (RF)**  **spectrum used**  **for control**  **of the**  **UAS and**  **associated equipment**  **that is**  **part of**  **the UAS**  **(i.e., sensors,**  **cameras, etc.)** **.** Listed below are the frequency specifications for the DJI Phantom 2 Vision+ UA.	As the unitwill be used to inspect cellular sites operating on similar frequencies, it’s important to note that both the UA manufacturer and wireless carriers’ Radio Frequency Engineers agree there will be no interference or noise caused by the UA because of RF signal interference mitigation equipment installed in all towers. Additional specifications can be found in attached User Manual. a. Frequency	Specifications: i. Remote	Controller	operating	frequency: 5.728GHz

-5.85GHz ii. RC Communication Distance: CE Compliance: 400m; FCC Compliance: 800m iii. RC	Receiver	Sensitivity:

-93dBm iv. RC Transmitting Power: CE Compliance: 25mW; FCC Compliance: 100mW v. Range	Extender	Operating	Frequency:	2412MHz

-2462MHz Regarding	the Unmanned	Aircraft	PIC 4. **Petitioners should**  **describe the**  **qualifications required**  **of any**  **PIC(s) who**  **will be**  **directly responsible**  **for the**  **operation of**  **the UAS,**  **including information**  **such as:**  **the level**  **of airman**  **certificate held;**  **any applicable**  **training related**  **to the**  **operation; and**  **any minimum**  **hours of**  **flight experience**  **required by**  **the PIC(s),**  **both total**  **flight time**  **and the**  **time with**  **the particular**  **UAS. If**  **the operation**  **would use**  **visual observers,**  **petitioners should**  **describe their**  **roles**

**and qualifications** 

. Towersource engages in an aggressive training program to familiarize all PICs with the DJI Phantom 2 Vision+. The current policy requires all PICs to watch the comprehensive video tutorials and log two hours offlight time at low altitudes before attempting higher

-level flights. Currently, no Towersource PICs hold airman certifications. Our current pairing of PICs have logged almost 50 hours offlight time with the UA. During flights, there is one PIC and onevisual observer to maintain	the	highest	level	of	saf ety	standards. 5. **Petitioners should**  **describe the**  **medical standards**  **and certification**  **of the**  **PIC(s) directly**  **responsible for**  **the operation**  **of the**  **UAS**

. All Towersource PICs have First Aid and CPR training from the Red Cross. All certifications are in good standing	and	not	expired. Regarding	the	Operation	of	the	Unmanned	Aircraft 6. **Petitioners should**  **fully describe**  **their intended**  **UAS operation(s).**  **Petitioners should**  **describe how**  **the proposed**  **operation(s) would**  **not adversely**  **affect safety,**  **or how**  **they would**  **provi de**  **a level**  **of safety**  **at least**  **equivalent to**  **that provided**  **by the**  **rule from**  **which exemption**  **is sought.**  **Petitioners should**  **address any**  **plans to**  **implement clearly**  **defined operational**  **borders and**  **procedures	to	ensure public	safety,	which	includes	persons	and**  **p roperty	both**  **in	the	air	and	on	the	ground**

. a. Scope of Work: Towersource UA will engage in the following telecommunications

-based activities: quality control audit, post-construction inspection, microwave path survey, RF line

-of

-site, port availability, rad center verification, access road survey, crane staging troubleshooting, rooftop inspections, regulatory inspections, lightning rod inspection, FAA “nested/obstructed lighting” inspections, balloon tests, wildlife audits, structural	integrity	investigation issues. b. The Reason for the Work: The entirety of the list above involves the UA tracking alongside the tower to investigate specific issues that may appear during a tower’s life cycle. Without an UA, these inspections and audits require physical climbing ofa tower conducted by trained tower crews. With over 50 reported tower-related fatalities since 2008, using a UA to inspect a site is remarkably safer than doing the same inspection with climbers. Additionally, the drone will simply be used to fly up the side of the tower, then come back down

—there is no danger of crossing paths with other aircrafts	or	flying	over	crowded	areas.	Flying	above	200	feet	will	be	required, as	some	towers	can	reach	much	higher400	feet	or	more

. c. Public and Property Safety: Towersource’s UA will be flown over the compound ofthe site, which will be empty aside from the PIC and the visual observer. No crowds or onlookers will be within the UA’s flight path. The property	over	which	the	drone	will	be	flying	will	be	owned	by	our	clients	and will	be	in	no	danger	of	damage. 7. **Petitioners should**  **specify the**  **proposed maximum**  **operating speed**  **and altitude,**  **and describe**  **minimum flight**  **visibility and**  **distance from**  **clouds for** **their intended**  **operation(s). Petitioners**  **should describe**  **potential ha** **zards**

**and safety**  **mitigations associated**  **with these**  **proposed conditions.**  **These issues**  **can be**  **addressed in**  **the petition,**  **an Operations**  **Manual, or**  **similar document** 

. Towersource will operate the UA between 100

-400 feet in order to inspect cell towers. Maximum speed will be between 2m/s and 4m/s. The company’s policy requires high visibility, clear days with no rain and no clouds in order to pilot the UA

. Because most ofthe drone’s flights require a single

-axis raise in	altitude,	followed	by a	single

-axis	rotation	around	a	tower,	very	few hazards	exist on proposed flights. Operating close to a	tower poses some degree ofrisk; however, that	risk	is	mitigated	with	the	help	of	having	both	a	PIC	and	a	visual	observer. **8. Petitioners**  **should describe**  **the characteristics**  **of the**  **area of**  **intended operation(s)**  **and the**  **associated potential**  **hazards, in**  **accordance with**  **the statutory**  **mandate under**  **Section 333**  **regarding proximity**  **to populated**  **areas. These**  **issues can**  **be addressed**  **in the**  **petition, an**  **Operations Manual,**  **or similar	document** **.**The	vast	majority	of	the UA’s audits	will	take	place	in	rural	areas with towers located on private property with no unrelated onlookers in the immediate area. Most cell towers that require UA inspections are located in these rural	areas. 9. **Petitioners should**  **describe if**  **they intend**  **to operate**  **in the**  **proximity of**  **any airports,**  **in accordance**  **with the**  **statutory mandate**  **under Section**  **333 regarding**  **proximity to**  **airports**

. Towersource will no operate within any five miles	ofan	airport,	adhering	to	all	Section	333	mandates	regardingthe	subject

. 10. **The UAS**  **must be**  **operated within**  **visual line** **- of**  **- sight**  **(VLOS), in**  **accordance with**  **the statutory**  **mandate under**  **Section 333(b)(1).**  **Petitioners should**  **describe how**  **they intend**  **to comply**  **with his**  **mandate.** The UA will be used for tower inspections and audits. Since it is Towersource’s internal policy for the PIC to stand within the tower compound and be accompanied by a visual observer, achieving the VLOS policies will always be in accordance to Section 333(b)(1) and there	will	never	bea	situation	in	which	the	PIC	cannot	visually	seethe	UA. 11. **Petitioners should**  **describe any**  **procedures they**  **would implement**  **for conducting**  **a preflight**  **safety risk**  **assessment to**  **determi ne**  **that the**  **UAS is**  **in a**  **condition for**  **safe flight**  **(14 CFR**  **§ 91.7(b))**  **and that** **the planned**  **operation can**  **be completed**  **safely. These**  **procedures can**  **be addressed**  **in the**  **petition, an**  **Aircraft Flight**  **Manual, Operations**  **Manual, or**  **similar document** 

. Towersource will follow all internal, OHSA

-driven policies as well as following the policies and standards presented in the DJI operations manual (see attached). Below is a select grouping	of	the	preflight	checks. a. Flight	Environment	Requirements: i. Do not use the aircraft in severe weather conditions. These include wind	speed	exceeding	category	4,	snow,	rain	and	smog ii. Fly	in	open	fields	as	numerous	high	buildings	and	steel	structures	may affect	the	accuracy	of	the	onboard	compass iii. Keep the AU away from obstacles, high voltage power lines, tress or bodies	of	water	when	in	flight. iv. Do not fly the aircraft within no-fly zones specified by local laws and regulationsb. Preflight	Checklist: i. Remote Controller, smart battery, Range Extender and smartphone are	fully	charged ii. Propellers	are	mounted	correctly iii. Gimbal	clamp	has	been	removed iv. Dampening	absorbers	are	in	good	condition,	not	broken	or	worn v. Anti

-drop	kits	have	been	mounted	correctly vi. Camera	lens	cap	has	been	removed vii. Micro

-SD	card	has	been	inserted	if	necessary viii. Gimbal	is	functioning	as	normal ix. Motors	can	start	and	are	functioning	as	normal x. DJI	Vision	App	can	connect	to	the	camera 12. **If petitioners**  **intend to**  **conduct operations**  **which have**  **existing requirements**  **to	notify	Flight	Standards	District	Offices	(FSDOs)	prior	to	operations**
**– such	as**  **motion picture**  **and television**  **filming, or**  **pipeline and**  **power line**  **patrol**
**– petitioners**  **should describe**  **their intended**  **coordination in**  **this regard**  **for their**  **proposed operation(s).**  Towersource does not intend to conduct operations requiring	this	type of	coordination.