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February 9th, 2016

Attn:

U. S. Department of Transportation Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Ave, SE Washington, DC 20590

RE: Anthony Verbsky / T-Cubed Home Inspection and Arial Filming LLC

Hi my name is Anthony Verbsky and I am writing to request and exemption from the 

requirements of title 14 of the code of federal regulations so that I can operate my an Unmanned 

Aircraft System (Tarot X8 System). I will specifically address the following sub-sections of 

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA).

61.113(a)

61.113(b)

91.7(a)

91.121

91.151(b)

91.405(a)

91.407(a)(1)

91.409(a)(1)

91.409(a)(2)

91.417(a) & (b)

Anthony Verbsky

President / Owner 

6800 S. Pennsylvania St.

Centennial, CO

720-985-1986

tcubedhomeinspection@gmail.com
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System

LOL Loss of Link 

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) 

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
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SUMMARY

T-Cubed Home Inspection and Arial Filming LLC seeks exemption from the requirements of 14 

C.F.R. 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System (Tarot X8 System)

pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This 

exemption will permit T-Cubed Home Inspections and Arial Filming LLC to operate an 

Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and 

photography of primarily construction sites, residential and commercial real estate, community 

devolopements, and agricultural projects and associated cites.

INTRODUCTION AND INTERESTS OF THE PETITIONER

T-Cubed Home Inspection and Arial Filming LLC is primarily a home inspection business for 

the real estate market, which is additionally being sought out by clients to film events and 

activities which are not part of the real estate market. We will primarily use the drone to conduct 

inspection of areas of the home that can not be reached safely, like a roof of a 2 -3 story home. 

The objective of T-Cubed Home Inspection and Arial Filming LLC in conjenction with our 

Unmanned Aircraft System (Tarot X8 System) Aerial Operations is to provide a very detailed

and simultaneously safe visual inspection or visual capture of an activity or event. I will provide 

a short list of our current services that we would like to offer to our clients:

• Construction Inspections

• Real-estate Inspections

• Home Buyer Inspections

• Home Seller Inspections

• Warranty Inspections 

• Time lapse photography and 3D video footage for Real-estate Developer Projects and 

Communities

• Time lapse photography and 3D video footage of large scale projects like football 

stadiums and associated partners properties during the construction

• Video footage capture for agriculture related needs

Personal Information:

I currently teach advanced mathematics at both the high school and college level and will start inspecting 

homes this summer. My students and I have been building drones for 3 years and understand every 

component and how they interact with each other. Our main mission was to mathematically recreate the 

flight path of the drone, and after we completed that task we moved into propulsion studies and will start 

a battery usage vs payload project in the fall. We routinely record video and take arial pictures for 

outdoor school events and because of this we have created safety protocal to protect ourselves and our 

community. One of our new missions is to make drones safer for people like me who want to use drones 

commericially, so we are developing more formal safty protocals and creating avenues to share these 

ideas. Additionally, we are creating a very detailed step by step video series on how to build the “fully 

loaded” Tarot X8 Drone and Filming System. Each and every component and its associated use and 
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interaction with other components will be discussed in its entirety. I have safely trained over 50 students 

over a 3 year period on how to build, diagonose mulfunctions, repair, and fly the DJI F450 Quadcopter 

and the DJI F550 Hexcopters, which are identical to my Tarot X8 System except for the camera system 

and the Tarot X8 frame. 

I have the support of my school, district and community and because of this support we have access to the 

whole campus which gives us a very large and safe practice space. Over that last three years I have had 

the opportunity to log in over 100 hours of flight time with Quadcopters, Hexacopters and Octocopters. 

We understand what it means to overprop and underprop. We understand what happens when it is 

overweight and you swich from manual mode to ATTI mode and then hit the Thottle lock switch. We 

understand the importance of calibration of ALL components that require calibration. We understand 

what it means to push a drone to its extreme performance limits. Why do we know this? We have 

crashed hard, and may I add repeatedly! But, we have learned from our controled experiements and 

mistakes and with each year and each class less mistakes are made and more saftely proticals are set to 

protect us from making the same mistake and prevent other potential mistakes.

Previous to my teaching career I built over 100 houses and associated decks, finished over 50 basements 

from start to finish, and during this time in my life worked on many construction sites with associated cite 

superintendents. I have experience with worksite saftely protical and associated safety personal and fully 

understand the dangers and penalties associated with not following the rules set in place to protect the 

workers and people around them. 

I feel confident that my unique experiences and skill sets will make me a good canidate to receive this 

exemption that I am seeking. I am also smart enough to still be nervous about flying a drone “near” the 

public and within the community, and I firmly believe that anyone who is not nervous does not 

understand the potential dangers that can be caused by one simple malfunction or human error. 

BACKGROUND

Unmanned Aircraft Systems: Tarot X8 System

T-Cubed Home Inspection and Arial Filming LLC seeks an exemption to operate Tarot X8

system for compensation or hire within the NAS. The Tarot X8 system is vertical takeoff and 

landing (VTOL) Unmanned Aircraft (UA) with a DJI Ground Control Station (GCS) with 

multiple control options. 

Control Option1: One person has the capability to simulateously fly and record video with 1 axis 

gimbal control with no ability to control the camera functionality using one 12 channel Walkera 

Devo 12 tranmitter and reciever. 

Option 2: One person has the option to fly atuonomously within line of sight using an I-Pad with 

the DJI Ground Control Application with preset flight path. Once the Tarot X8 is verified to be 

on course the operator can use the Walkera Devo 12S to simultaneously control all 3 axis of the 

gimbal, switch the camera between picture and video mode record, and most importantly control 

the optical RC zoom lens. 
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Contol Option 3 (Prefered): Two person operation using two Walkera Devo 12S transmitters. 

One transmitter controls the Tarot X8 and the other controls the Arris Gimbal and Sony Nex5 

Camera.

This Tarot X8 System is fully loaded with a current gross weight of 31 lbs, but has the ability to 

carry up to a gross weight of 45 lbs. The Tarot X8 has eight 15 inch propellers and a diagonal 

dimension of 58 inches. This model has upgraded motors and can support 18 inch propellers 

which would only be needed if one needed to reach the maximum 45 lb gross weight capabilities 

of this system. This system is designed to manually be controled via the Walkera Devo 12S 

transmitter in ATTI mode, which is basically the NAZA M V2 controling speed and altitude 

mixtures. I will add a link at the end of this paragraph to more fully explain this process. This 

system is also designed to be controled via an I-Pad and associated Gound Control Station 

Application on a preset flight path in GPS Mode. When setting the preset flight path one has the 

ability to control altitude and speed between dedicated points called ,way points. One has the 

option to use the full 100% potential of the Tarot X8 system with the same controling speed and 

altitude mixtures as ATTI mode, but I must add that any movement over 10 mph would be 

considered extreme for my applications. Additionally this system is controled by the NAZA M 

V2 control system and it can be programed to restrict altitude to for example 200 feet, and can 

restrict distance of Tarot X8 system from transmitter to for example 1000 feet. If one of these 

restrictions is met the Tarot X8 will return home and land regardless of being in Manual, GPS, or 

ATTI Mode. 

Extra Safty Options:

 This system will run and safely land even if two motors fail,which is my main reason for 

choosing this unit. 

 If any abnormality occurs during a flight I can just flip switch on the Walkera Devo 12S 

to activate FailSafe Mode, regardless of being in ATTI or GPS Mode, and it will return 

home and land.

 I choose not to let my Tarot X8 system to run in Manual Mode due to the its high 

performance capabilities by programming the Walkera Devo 12S not to allow access to 

Manual Mode.

 During ATTI mode, my traditional flight mode with Devo 12S nonautonomous control, 

when I choose to hover I can switch to ThottleLock which will allow the Tarot X8 to 

hover in place and all flight functions will be disabled except for the thottle lever which 

can be adjusted if unit is slightly decending or acending. Then one can switch the 

ThottleLock off and return to normal flight.

 This Tarot X8 System has an added Walkera Telemetry Sensor with added voltage 

sensors, propeller rpm sensor, and GPS Module which integrates with the Walkera Devo 

12S transmitter and Freeworld 10 inch HD display. All information is displayed on 

screen during flight and sound warning alerts can be activated if preset limits are reached 

allowing the pilot to safely return Tarot X8 System home.
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 The NAZA M V2 control system on the Tarot X8 System has multiple battery warning settings 

options. The first layer of protection sets off an audible warning. The second layer of protection 

forces the Tarot X8 System to return home and land.

My Tarot X8 system that will be operated by T-Cubed Home Inspection and Arial Filming LLC

will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 

C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, 

Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, T-Cubed Home Inspections and Arial Filming LLC, pursuant to the provisions of the 

Federal Aviation Regulations (14 C.F.R.: 11.61) and the FAA Modernization and Reform Act of 

2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator to commercially operate the Tarot X8, UAS in the National Airspace 

System (NAS), and for an exemption from the requirements of 14 C.F.R : 61.113(a) & (b), 

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

In consideration of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, T-Cubed Home Inspections and Arial Inspections LLC

operation of Tarot X8 System UAS meets the conditions of FMRA Section 333 and therefore, 

will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, T-Cubed Home Inspections and Arial Inspections LLC requests relief from 

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections 

set forth requirements for maintenance that only apply to aircraft with an airworthiness 

certificate. 

T-Cubed Home Inspections and Arial Inspections LLC submits that the requested relief is proper 

since an equivalent level of safety will be ensured. T-Cubed Home Inspections and Arial 

Inspections LLC Tarot X8 will be personally operated, inspected, and maintained by me, 

Anthony Verbsky, All modifications, preventive maintenance, and calibration on the UAS using 

the methods, techniques, software, applications and practices prescribed in the operating 

documents (i.e., Monthly Maintenance Log, Tarot X8 Instruction Manual, NAZA V2 Instruction 

Manual, Arris X6 Gimbal Manual, Ground Control Station Manual, Walkera Devo 12S Manual, 

Walera Telmetry Manual). Furthermore, T-Cubed Home Inspection and Arial Filming LLC will 

document and maintain all maintenance records for the Tarot X8 System UAS. 

T-Cubed Home Inspection and Arial Filming LLC seeks relief from Section 91.7(a), entitled 

Civil aircraft airworthiness, because the Tarot X8 System UAS does not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, T-Cubed Home Inspection 

and Arial Filming LLC submits that they will ensure that the Tarot X8 System UAS is in an 

airworthy condition, prior to every flight, by determining that the UAS are in compliance with 

the operating documents (i.e., Monthly Maintenance Log, Tarot X8 Instruction Manual, NAZA 
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V2 Instruction Manual, Arris X6 Gimbal Manual, Ground Control Station Manual, Walkera 

Devo 12S 

T-Cubed Home Inspection and Arial Filming LLC also seeks an exemption from the 

requirements of Section 91.121, entitled Altimeter Settings, as the Tarot X8 System UAS will not 

have a typical barometric altimeter onboard. However, altitude information of the Tarot X8 UAS

will be provided to the PIC via Global Positioning System (GPS) equipment and radio 

communications telemetry data link, which downlinks from the UA to the GCS for active 

monitoring of the flight path. This altitude information, combined with T-Cubed Home 

Inspection and Arial Filming LLC operation of the Tarot X8 UAS within visual line of sight, at 

or below 200 feet AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, T-Cubed Home Inspection and Arial Filming LLC seeks an exemption from the 

requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. TCubed Home Inspection and Arial Filming LLC submits that safety will not be affected by

operation of the Tarot X8 System UAS during daylight hours in visual meteorological conditions 

(VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of 

approximately 25 minutes. Battery power indicators are also able to show exactly how much 

battery power is left, as well as how much time is needed to return safely back to point of 

takeoff.

In accordance with 14 C.F.R. § 11.81, T-Cubed Home Inspection and Arial Filming LLC 

provides the following information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

Anthony Verbsky

President / Owner 

6800 S. Pennsylvania St.

Centennial, CO

720-985-1986

tcubedhomeinspection@gmail.com

tcubedarialfilming@gmail.com
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B. The Specific Sections Of 14 C.F.R. From Which T-Cubed Home Inspection and Arial 

Filming Seeks Exemption. 

1. The T-Cubed Home Inspection and Arial Filming LLC Seeks Exemption from The 

Requirements Of Section 61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command 

(PIC) of an aircraft that is carrying passengers or property for compensation or hire; 

nor may that person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if—

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

2. T-Cubed Home Inspection and Arial Filming LLC Seeks Exemption From The 

Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. T-Cubed Home Inspection and Arial Filming LLC Seeks Exemption From The 

Requirements Of Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: 

(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 
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(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. 

4. T-Cubed Home Inspection and Arial Filming LLC Seeks Exemption From The 

Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following: 

(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. 

5. T-Cubed Home Inspection and Arial Filming LLC Seeks Exemption From The 

Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each 

owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter[.] 

6. T-Cubed Home Inspection and Arial Filming LLC Seeks Exemption From The 

Requirements Of Section 91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 43.7 

of this chapter[.] 

7. T-Cubed Home Inspection and Arial Filming LLC Seeks Exemption From The 

Requirements Of Sections 91.409(a)(1) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by § 43.7 of this chapter; or 
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(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter. 

8. T-Cubed Home Inspection and Arial Filming LLC Seeks Exemption From The 

Requirements Of Sections 91.417(a) And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the 

following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods specified 

in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and each 

engine, propeller, rotor, and appliance of an aircraft. The records must include--

(i) A description (or reference to data acceptable to the Administrator) of the 

work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the aircraft 

for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, 

rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the aircraft 

and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety

directives including, for each, the method of compliance, the AD or safety

directive number and revision date. If the AD or safety directive involves 

recurring action, the time and date when the next action is required. 
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(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained until 

the work is repeated or superseded by other work or for 1 year after the work is 

performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service. 

C. The Extent Of Relief T-Cubed Home Inspection and Arial Filming LLC Seeks And The 

Reason T-Cubed Home Inspection and Arial Filming LLC Seeks The Relief. 

1. Extent Of Relief T-Cubed Home Inspection and Arial Filming LLC Seeks And The Reason 

T-Cubed Home Inspection and Arial Filming LLC Seeks Relief From Section 61.113(a) And 

(b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in 

command, is requested to the extent necessary to allow a PIC holding a private pilot or higher 

level certificate, as well as a current and valid airman medical certificate, and who has met 

certain flight-hour and currency requirements, to conduct the proposed UAS flight operations for 

compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a 

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

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

(2) The aircraft does not carry passengers or property for compensation or hire. 

As set forth more fully below, T-Cubed Home Inspection and Arial Filming LLC submits that an 

equivalent level of safety will be maintained because no PIC will be allowed to operate the Tarot 

X8 System UAS unless that PIC has met certain flight-hour and currency requirements, 

demonstrating that the PIC is able to safely operate either the Tarot X8 System UAS in a manner 

consistent with the operations specifications as described in this exemption, including evasive 

and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, 

vehicles and structures.
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Further, T-Cubed Home Inspection and Arial Filming LLC submits that all flights of the Tarot 

X8 System UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be 

incidental to T-Cubed Home Inspection and Arial Filming LLC business; and (2) will not carry 

passengers or property for compensation or hire. 

2. Extent Of Relief T-Cubed Home Inspection and Arial Filming Seeks And The Reason TCubed Home Inspection and Arial Filming Seeks Relief From Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent 

required to allow T-Cubed Home Inspection and Arial Filming to determine that the Tarot X8 

System UAS are in airworthy condition prior to every flight by ensuring that the UAS is in 

compliance with the operating documents (i.e., T-Cubed Home Inspection and Arial Filming

Aerial Operations Manual, Monthly Maintenance Log, and Tarot X8 System Instruction 

Manual). 

T-Cubed Home Inspection and Arial Filming seeks the requested relief because the Tarot X8 

System UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. Therefore, T-Cubed Home Inspection and Arial Filming will ensure that the Tarot X8 

System UAS are in airworthy condition based upon its compliance with the operating documents 

(i.e., Monthly Maintenance Log, and Tarot X8 System) prior to every flight, and further, 

determine that the aircraft are in condition for safe flight, as stated in the conditions and 

limitations below.

3. Extent Of Relief T-Cubed Home Inspection and Arial Filming Seeks And The Reason TCubed Home Inspection and Arial Filming Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight 

operations of the Tarot X8 System UAS, which utilize a barometric pressure sensor, GPS 

equipment, and a radio communications telemetry data link to downlink altitude information 

from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any 

altitude information concerning UAS operations be reported to air traffic control (ATC) in feet 

above ground level (AGL), T-Cubed Home Inspection and Arial Filming seeks the requested 

relief because the Tarot X8 System UA’s altimeter may be set on the ground to zero feet AGL, 

rather than the local barometric pressure or field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought 

to the extent necessary to comply with the applicable conditions and limitations stated below. As 

more fully set forth herein, an equivalent level of safety will be maintained since the Tarot X8 

System UAS are equipped with a barometric pressure sensor and GPS equipment, which 

automatically ensures that a ground level pressure setting will be established prior to each flight, 

and provides the PIC with altitude information of the UA on the heads-up display of the GCS. 
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4. Extent Of Relief T-Cubed Home Inspection and Arial Filming Seeks And The Reason TCubed Home Inspection and Arial Filming Seeks Relief From Section 91.151(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is 

requested to the extent required to allow flights of the battery powered Tarot X8 System UAS

during daylight hours in visual meteorological conditions (VMC), under visual flight rules 

(VFR), for a total duration of 23 minutes. T-Cubed Home Inspection and Arial Filming seeks the 

requested relief because without an exemption from Section 91.151(b), the flight time duration 

of the battery powered Tarot X8 System UAS will severely constrain the practicality of any 

aerial video or still photo flight operations that T-Cubed Home Inspection and Arial Filming

proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the Tarot X8 System UAS, the 

Tarot X8 System operating documents, and T-Cubed Home Inspection and Arial Filming

proposed operating limitations, ensure that T-Cubed Home Inspection and Arial Filming will 

safely operate the battery powered Tarot X8 System UAS during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to 

fly for a total duration of 23 minutes.

5. Extent Of Relief T-Cubed Home Inspection and Arial Filming Seeks And The Reason TCubed Home Inspection and Arial Filming Seeks Relief From Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). 

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to 

aircraft with an airworthiness certificate, T-Cubed Home Inspection and Arial Filming requests 

relief from these Sections because the Tarot X8 System UAS do not require airworthiness 

certificates. As set forth more fully below, the Tarot X8 System UAS meet the conditions of 

FMRA Section 333 for operation without an airworthiness certificate. Accordingly, T-Cubed 

Home Inspection and Arial Filming will use trained technicians to perform maintenance, 

alterations, or preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed in the UAS operating documents (i.e., the T-Cubed Home Inspection and Arial 

Filming Aerial Operations Manual, Monthly Maintenance Log, and Tarot X8 System Instruction 

Manual). Furthermore, T-Cubed Home Inspection and Arial Filming will document and maintain 

all maintenance records for the Tarot X8 System UAS. 

D. The Reasons Why Granting T-Cubed Home Inspection and Arial Filming Request 

Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing T-Cubed Home 

Inspection and Arial Filming to safely, efficiently, and economically perform aerial video and 

photography of construction, real estate, and properties in Illinois.
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Additionally, use of the Tarot X8 System UAS will decrease congestion of the NAS, reduce 

pollution, and provide significant benefits to the economy. Notably, the benefits of T-Cubed 

Home Inspection and Arial Filming proposed operation of the Tarot X8 System UAS will be 

realized without implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The Tarot X8 System UAS are battery powered and serve as a safe, efficient, and economical 

alternative to a unsafe practice of climbing onto roofs of homes. It will provide areal video and 

photos to the inspectors to insure the public gets a well overview of the home.

2. The Public Will Benefit From The Safety And Efficiency Of The Tarot X8 System UAS. 

The DJI Phantom 3 UAS (weighing approximately 31 pounds at their maximum gross weight

with diagonal dimension of 58 inches, and with no fuel on board), has less physical potential for 

collateral damage to life and property on the ground, and in the air.

3. Performing Aerial Video and Photography Operations With The Tarot X8 System UAS

Will Benefit The Economy. 

By operating the Tarot X8 System UAS, companies such as T-Cubed Home Inspection and Arial 

Filming, can remain competitive and profitable, and therefore, provide greater job stability to 

employees and contractors, which will ultimately contribute to growth of the U.S. economy. 

Improved Safety for the inspector will result in less medical accidents from inspectors falling 

from roofs ext. Resulting in worker compensation claims and other lawsuits from injuries. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, 

T-Cubed Home Inspection and Arial Filming proposed operation of the Tarot X8 System UAS

will not implicate any privacy issues. Specifically, the Tarot X8 System UAS will be operated 

only in compliance with operating documents (i.e., T-Cubed Home Inspection and Arial Filming

Aerial Operations Manual, Monthly Maintenance Log, and Tarot X8 System Instruction Manual) 

which requires property owner involvement as well as local law enforcement notification, and in 

accordance with the Federal Aviation Regulations, including the minimum altitude requirements 

of 14 C.F.R. § 91.119. 

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 T-Cubed Home Inspection and Arial Filming Seeks Exemption. 
15

1. Reasons Why The Tarot X8 System UAS Meet The Conditions Of The FAA 

Modernization and Reform Act of 2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated with the 

unmanned aircraft and its operation, T-Cubed Home Inspection and Arial Filming operation of 

the Tarot X8 System UAS meet the conditions of FMRA Section 333, and will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness certification and sets 

forth requirements for considering whether a UAS will create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the 

following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later 

than 180 days after the date of enactment of this Act, the Secretary of Transportation 

shall determine if certain unmanned aircraft systems may operate safely in the 

national airspace system before completion of the plan and rulemaking required by 

section 332 of this Act or the guidance required by section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their size, 

weight, speed, operational capability, proximity to airports and populated 

areas, and operation within visual line of sight do not create a hazard to users 

of the national airspace system or the public or pose a threat to national 

security; and

(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems identified 

under paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under this section 

that certain unmanned aircraft systems may operate safely in the national airspace 

system, the Secretary shall establish requirements for the safe operation of such 

aircraft systems in the national airspace system. 

In seeking this exemption, T-Cubed Home Inspection and Arial Filming submits that the DJI 

Phantom 2 Vision, Plus UAS can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the Tarot X8 System UAS; (b) the pilot certification 

requirement; and (c) the specific operating limitations. 

a. The Specifications Of The Tarot X8 System UAS Demonstrate Its Safe Characteristics.

The Tarot X8 System UAS does not create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security considering its size, weight, speed, and operational 

capability. 
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3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not 

Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to 

every flight, T-Cubed Home Inspection and Arial Filming will ensure that the Tarot X8 System

UAS is in an airworthy condition based upon the UAS’s compliance with its operating 

documents and as stated in the conditions and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not 

Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because the 

altitude information of the Tarot X8 System UAS will be provided to the PIC via GPS equipment 

and a radio communications telemetry data link, which downlinks from the UA to the GCS for 

active monitoring of the flight path and altitude. This altitude information, combined with TCubed Home Inspection and Arial Filming operation of the Tarot X8 System UAS within visual 

line of sight, at or below 200 feet AGL, will ensure a level of safety equivalent to Section 

91.121. The altitude information will be generated by GPS equipment installed onboard the 

aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the 

UAS at ground level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 

11158, 11159, 11160, 11161). 

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not 

Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. 

Section 91.151(b) as a result of (1) the technical specifications of the Tarot X8 System UAS; (2) 

the limitations on the proposed flight operations; and (3) the location of the proposed flight 

operations. Accordingly, T-Cubed Home Inspection and Arial Filming will ensure that it will 

safely operate the battery powered Tarot X8 System UAS during daylight hours in VFR 

conditions, with enough battery power to fly for a total duration of 25 minutes. 
17

Furthermore, safety will be ensured as the Tarot X8 System UAS provide audible and visual 

warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first warning 

occurring at approximately 33% remaining battery power, and again at approximately 10% 

remaining battery power. At the critically low battery level, the Tarot X8 System UAS will 

descend and land automatically. 

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely 

Affect Safety. 

In seeking this exemption, T-Cubed Home Inspection and Arial Filming submits that the 

equivalent level of safety with regard to the regulatory maintenance and alteration requirements 

established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will 

be met because T-Cubed Home Inspection and Arial Filming will use trained technicians to 

perform maintenance, alterations, or preventive maintenance on the UAS using the methods, 

techniques, and practices prescribed in the operating documents (i.e., T-Cubed Home Inspection 

and Arial Filming Aerial Operations Manual, Monthly Maintenance Log, and Tarot X8 System

7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) 

and 14 C.F.R. § 21.16 entitled Special Conditions, T-Cubed Home Inspection and Arial Filming

requests that the FAA prescribe special conditions for the intended operation of the Tarot X8 

System UAS, which contain such safety standards that the Administrator finds necessary to 

establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 

C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAS for the 

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

States for compensation or hire. FMRA Section 333 sets forth the requirements for considering 

whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat 

to national security; and further, provides the authority for such UAS to operate without 

airworthiness certification in accordance with any requirements that must be established for the 

safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the DJI Phantom 3 UAS, since the airworthiness regulations of 14 

C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or 

unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the 

following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, 

he prescribes special conditions and amendments thereto for the product. The special 
18

conditions are issued in accordance with Part 11 of this chapter and contain such safety 

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to 

establish a level of safety equivalent to that established in the regulations. 

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may

prescribe special conditions for Leading Edge’s intended operation of the Tarot X8 System UAS, 

which contain such safety standards that the Administrator finds necessary to establish a level of 

safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b).

• A Summary That Can Be Published In The Federal Register, stating: The 

Rules From Which T-Cubed Home Inspection and Arial Filming Seeks Exemption: 

T-Cubed Home Inspection and Arial Filming seeks exemption from the requirements of 

14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption T-Cubed Home Inspection and Arial

Filming Seeks: 

This exemption will permit T-Cubed Home Inspection and Arial Filming to commercially 

operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video 

and photography over certain areas of Colorado..

• Any Additional Information, Views, Or Arguments Available To Support TCubed Home Inspection and Arial Filming Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS 

may operate safely in the NAS. As such, T-Cubed Home Inspection and Arial Filming request 

for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 

11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security; and 

further, provides the authority for such UAS to operate without airworthiness certification. 

As discussed in detail above, T-Cubed Home Inspection and Arial Filming will operate the Tarot 

X8 System UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, 

or otherwise pose a threat to national security. 

CONCLUSION
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As set forth herein, T-Cubed Home Inspection and Arial Filming seeks an exemption pursuant to 

14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), 

which will permit safe operation of the Tarot X8 System UAS commercially, without an 

airworthiness certificate, for the limited purpose of conducting aerial video and photography

over certain areas of the Illinois. By granting this Petition, the FAA Administrator will be 

fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while 

also advancing the interests of the public, by allowing T-Cubed Home Inspection and Arial 

Filming to safely, efficiently, and economically operate the Tarot X8 System UAS commercially 

within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, T-Cubed Home Inspection and Arial 

Filming respectfully requests that the Administrator grant this Petition for an exemption from the 

requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the 

Tarot X8 System UAS commercially for the purpose of conducting aerial video and photography 

over certain areas of Illinois.

Dated: February 10th, 2016

Thanks for your consideration

Anthony Verbsky

President / Owner 

6800 S. Pennsylvania St. 

Centennial, CO, 80122

720-985-1986

tcubedhomeinspection@gmail.com

tcubedarialfilming@gmail.com

Appendices:

A) All instruction Manuals for Tarot X8 System

a. DJI NAZA V2 Control System Manual

b. DJI Ground Station Manual

c. Tarot X8 Frame and Electrical Manual

d. Walkera Devo 12S transmitter and receiver

e. Walkera Devo Telemetry Module and GPS sensor

f. ARRIS Zhao Yun Pro 3-Axis brushless Gimbal
20

https://drive.google.com/file/d/0B-AnuFLg4V5KZXV6WmVreDMyUkE/view?usp=sharing