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October 30, 2015

TransLab Inc.

Michael Rentoumis, President

28351 SE Highway 42

Umatilla, FL 32784

(352) 669-7729

labinfo@centurylink.net

Attention: FAA Administrator,

The following petition for exemption is prepared and filed in accordance with 14 CFR 11.81.

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulation form 14 CFR Part 21; 14 CFR 45.23(b); 14 CFR 61.113 (a) & (b); 14 CFR 

91.7(a); 14 CFR 91.9 (b)(2);14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119; 14 CFR 91.121; 14 

CFR 91.151(a); 14 CFR 91.203(a) & (b); 14 CFR 91.205 (b); 14 CFR 91.215(a) & (b); 14 CFR 

91.131 (d); 14 CFR 91.405 (a); 14 CFR 91. 407(a) (1); 14 CFR 91.409(a) (2); 14 CFR 19.417 (a) & 

(b)

Dear Administrator,

Pursuant to the Section 333 of the FAA Modernization and Reform Act of 2012 (The Reform 

Act) and 14 CFR Part 11, TransLab Inc., the operator of Small Unmanned Aircraft Systems (sUAS) 

equipped to conduct aerial photography and cinematography services hereby applies for an 

exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operations 

of its s UAS so long as such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333.

As described in more detail below, the requested exemption would permit the operation of 

small, unmanned sUAS under controlled conditions in the NAS that is both limited and 

predetermined. Approval of this exemption would thereby enhance safety and fulfill the 

Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “...establish 

requirements for the safe operations of such aircraft in the national airspace system.” Section 

333(c) of the Reform Act.

Regulations from which the exemption is requested:

14 CFR Part 21

14 CFR 45.23(b)

14 CFR 61.113(a) & (b)

14 CFR 91.7(a)

14 CFR 91.9 (b) (2)

14 CFR 91.103
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14 CFR 91.109

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.205 (b)

14 CFR 91.215 (a) & (b)

14 CFR 91.131 (d)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b)

The requested exemption would permit TransLab inc. to pursue commercial aerial data 

collection opportunities in providing services to clients using a small advanced sUAV in the 

following areas: Real Estate, Land Management/Surveying, Agricultural Modeling, Crop 

Monitoring Operations, Cell Tower Inspection, Infrastructure Inspection, Environmental

Property Assessment, Post-Disaster Assessment, Weddings, Training, and Marketing. TransLab 

Inc. requires that all sUAS flights will occur over private or controlled access property and will 

do so with the property owner’s consent and knowledge and only with people who have 

consented or otherwise have agreed to be within the UAS’ radius during filming and 

photography.

The employees of TransLab Inc. have demonstrated the ability to safely and effectively fly the 

very popular sUAS DJI Inspire 1. The DJI Inspire 1 is comprised of an unmanned aircraft (UA or 

Inspire 1) and a mobile transmitting/receiving unit. The Inspire is a quad-copter with a 

maximum gross weight of about 6.5 pounds. It is equipped with four rotors that are driven by 

electric motors powered by a rechargeable battery. The UAS has a maximum airspeed of 49

mph.

Public Benefit and Safety

For many reasons, this exemption would not adversely affect safety. The main reasons are the 

small size of the UAS’s used and the restricted controlled environment within which they will 

operate. We fit within that zone of safety (an equivalent level of safety) in which Congress 

envisioned that the FAA must, by exemption, allow commercial operations of UASs to 

commence immediately. Furthermore, due to the small size of the UASs and the controlled 

areas in which the Inspire 1 will operate, approval of the application presents no national 

security issue. Given the numerous benefits over conventional rotorcraft, including risk of 

carrying crew, high noise levels, and flammable fuel, the grant of the requested exemption is 

clearly in the public interest: TransLab Inc. proposes that the exemption we are requesting 

apply to civil aircraft that have the characteristics and that operate with the limitations listed 

herein. 
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Limitations and Conditions

These limitations and conditions to which TransLab Inc. agrees to be bound when conducting 

commercial operations under an FAA issued exemption are as follows:

1. The UAS will weigh less than 55 lbs.

2. The UAS may not be operated at a speed exceeding 87 knots (100 miles per hour)

3. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation

4. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components.

5. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins.

6. All operations must utilize a visual observer (VO) in addition to the pilot in command (PIC).

7. The sUAS PIC will be an FAA licensed airman holding a minimum of a Private Pilot certificate, 

current FAA medical certificate, and screening by the TSA. (Sport pilot license and driver’s 

license may be substituted).

8. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This 

requires the PIC to be able to use human vision unaided by any device other than corrective 

lenses, as specified on the PIC’s FAA-issued airman medical certificate or U.S. driver’s license. 

9. Maximum total flight time for each operational flight will be 30 minutes.

10. Flights will be terminated at 15% battery power reserve.

11. Flights will be operated at an altitude not to exceed 400 feet AGL; altitude must be 

reported in feet AGL.

12. UAS operator(s) will be trained and certified in the proper safety and operations of the UAS.

13. The UAS will only operate within a controlled area as defined in the factory manual under 

specifications.

14. The operator will post advisory notices around the controlled area, when appropriate.

15. The operator will have been trained in operation of UAS in general and received up-to-date 

information on the particular UAS to be operated as required.

16. If the UAS loses communication with the base station or loses its GPS signal, the UAS has 

the capability to return to a pre-determined location within the Security Perimeter and land.

17. The UAS has the ability to abort a flight in case of unpredicted obstacles or emergencies.

18. When flying the sUAS within five (5) miles of an airport, airport operators will be notified 

and the operator will give the right-of-way to avoid flying in the proximity of general aviation 

aircraft.

19. The UAS will only operate during daylight hours in Visual Meteorological Conditions (VMC) 

under visual flight rules (VFR).

Similar Exemptions

This petition is similar in all respects to relief previously requested in Grant of Exemption Nos. 

11062, 11109, 11112, and 11213.
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PIC Information

Kevin B. Torman: Private Pilot Certificate number 3818776, Issued 13 July 2015.

Thank you for taking the time to review our petition. Please feel free to contact me at (352) 

669-7729 for additional information or if clarifications are required.

Sincerely,

Michael Rentoumis

President

TransLab Inc.