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	below in	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	relief.	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	would	benefit	the	public	as	a	whole.	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	for	vulnerable	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	

expensive	wireless	network.		
(e) The	reasons	why	granting	the	exemption	would	not	adversely	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	of	flight	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: the	 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	 your	

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	pounds
iii. 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	unit	will	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	of	flight	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	

of	flight	time	with	the	UA.	During	flights,	there	is	one	PIC	and	one	visual	observer	to	

maintain	the	highest	level	of	safety	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	provide	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	property	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	of	a	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	higher	400	feet	or	more.	

c. Public	 and	 Property	 Safety:	 Towersource’s	 UA will	 be	 flown	 over	 the	

compound	of	the	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	 hazards	

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	of	the	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	of	risk;	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	of an	airport,	adhering	to	all	Section	333	mandates	regarding	the	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	be	a	situation	in	which	the	PIC	cannot	visually	see	the	UA.

11. Petitioners	 should	 describe	 any	 procedures	 they	 would	 implement	 for	

conducting	a	preflight	safety	risk	assessment	to	determine	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	

regulations
b. 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.