**CellInfo** LLC Page **1**

September 2 3 , 2015 U.S. Department of Transportation (DOT) Federal Docket Management System 1200 New Jersey Avenue, S.E. Washington, D.C. 20590 Dear Sir or Madam,
Pursuant to S ection 333 of the FAA Modernizat ion and Reform Act of 2012 ( FMRA), CellI nfo, LLC requests an exemption to permit unmanned aircraft system ( UAS) operations as described in this petition. CellInfo, LLC requests exemptions in order to legal ly operate UAS, the DJI Inspire 1, in the National Airspace System (NAS ) for the purpose of conducting aerial photography and video for site inspection of properties including cell phone towers and potential tower locations. CellInfo, LLC’s proposed operations will comply with all strict safety standards. Operations will take place in sparsely inhabited rural locations or within cell tower easements and occur at altitudes under 400 fee t above ground level using UAS less than 35 pounds by a pilot who has received the necessary training for safe op eration of the UAS. The proposed operations would not have an impact on any citizen’s privacy rights and will be in compliance w ith all privacy laws. Therefore , granting CellInfo , LLC’s exemption request would be in the public interest.
CellInfo, LLC is committed to finding the best opportunities for new wireless communication facilities and providing these opportunities to our trusted partners and developers. We have more signal information than any competing firm and unique software that allows us to efficiently identify new high opportunity and low risk tower site locations. We provide our sites to developers who get the site on the air with major wireless communication service providers such as Verizon, Sprint, T

- Mobile, and AT&T. The cell tower inspection industry does not operate at maximum efficiency or capability. We strongly believe that the utilization of a UAS for asset and location inspections is the necessary step for optimization of the industry. Seventy

- Five Park Plaza Boston, Massachusetts 02116 Tel +1 603 312 9141 Fax +1 617 322 0150 n ate@cellinfo .co www.cellinfo. co


## Petition for Exemption: Section 333 of the FAA **Modernization and Reform Act of 2012 CellInfo**  LLC Page **2**



## UAS **Specifications (DJI Inspire 1)**
**Aircraft Characteristics**  **Model** T600 **Motor Model** DJI 3510 **Propeller Model** DJI 1345 **Weight (including battery)** 2935 g **Dimensions** 438x451x301 mm 

## Aircraft **Performance Max Pitch Velocity**  300°/s **Max Yaw Velocity** 150°/s **Max Tilt Angle** 35° **Max Ascent Speed**  5 m/s **Max Descent Speed** 4 m/s **Max Speed** 22 m/s (not recommended) **Max Wind Speed Resistance** 10 m/s **Operating Temperature Range**

- 10° to 40°C **Max Flight Time** Approximately 18 minutes 

## Battery **Name** Intelligent Flight Battery **Model** TB47 **Capacity** 4500 mAh **Voltage** 22.2 V **Battery Type** LiPo 6S High voltage battery **Energy** 99.9 Wh **Net Weight** 570 g **Operating Temperature Range**

- 10° to 40°C **Max Charging Power** 180 W**CellInfo** LLC Page **3**



## Exemption Requests CellInfo, LLC requests exemption from the following regulations as well as any additional regulations that apply to the operation of the DJI Inspire 1 or similar UASs to the extent necessary to allow CellInfo, LLC to perform aerial data collection.
14 CFR § 61.113(a) a nd (b) 14 CFR § 91.7(a) 14 CFR § 91.119(c) 14 CFR § 91.121 14 CFR § 91.151(a)(1) 14 CFR § 91.405(a) 14 CFR § 91.407(a)(1) 14 CFR § 91.409(a)(1) and (2) 14 CFR § 91.417(a) and (b) 

## 14 CFR 61.113(a) **and (b) Private Pilot**  CellInfo, LLC will use specially trained staff to conduct the UAS operations. These individuals will each hold an FAA issued private pilot certificate and be thoroughly familiar and trained with their UAS’s operational and safety procedures. The UAS will not carry property for compensation or hire since it will be used solely to evaluate land and infrastructure in the furtherance of CellInfo, LLC’s clients’ primary business, the successful operation of infrastructure. However, the employees’ operation of the UAS wi ll not be incidental to their employment with CellInfo, LLC, and they will be compensated for such work. Without an exemption, the pilot would be required to hold a commercial pilot certificate under § 61.133. Moreover, the risk associated with the contempl ated operation is less than that of a traditional aircraft. Operations will take place within CellInfo, LLC’s clients’ geographic envelope. The UAS will fly at altitudes well below the permissible limits for other civil aircraft, eliminating the risk to ot her aircraft. Requiring a commercial pilot certificate would provide no appreciable safety benefit and would needlessly impose additional cost on CellInfo, LLC. Because the contemplated operations would not comply with § 61.113(b)(1) and none of the other exceptions in paragraph (a) apply, relief is needed from both paragraphs. 

## 14 CFR 91.7(a) Civil Aircraft Airworthiness CellInfo, LLC seeks the requested relief because the DJI Inspire 1 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, prior to every flight, CellInfo, LLC will ensure that the DJI Inspire 1 UAS is in an ai rworthy condition based upon a visual inspection, in order to determine that the UAS and its components are in compliance with its type desig n and operating documents, and that the aircraft can be operated safely.**CellInfo** LLC Page **4**



## 14 CFR 91.19(c) Minimum Safe Altitude Ce llInfo, LLC submits that the only relief it requires from § 91.119 is from the minimum altitudes listed in paragraph (c). Relief is requested because the UAS will be operating at a maximum 400 feet AGL. Since o perations at 500 feet or higher also pose a hei ghtened risk of collision with another aircraft, safety can only be assured through grant of this exemption. The UAS will not be operated within 5 NM of any airport and will only be operated with the consent of property manager and/or owner.


## 14 CFR 91.121 **Altimeter Setting** As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. Altitude information will be provided to the UAS pilot via a digitally encoded telemetric data feed, which downlinks from the aircraft to a ground

- based on

-screen display. This altitude information will be generated by equipment installed on board the aircraft using GPS triangulation, a digitally encoded barometric altimeter, radio altimeter, or any combination thereof. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the pilot. 

## 14 CRF 91.151 Fuel Requirements CellInfo, LLC does not intend to use the UAS for point

-to
- point flights and will not operate out of VLOS. The UAS will not require an airport to land. CellInfo, LLC w ill operate using a pre

- planned flight path. As such, there is no need for a time

- based excess fuel requirement. Rather it should be sufficient to require only as much additional excess flight capacity as necessary to safely land the UAS. We believe that 2 5% battery reserve is more than sufficient to meet this objective. The DJI Inspire 1 UAS as employs a “return to home” safety feature that will automatically return the UAS to the established “home” position upon its battery reaching a critical level. Therefore, an equivalent level of safety is certainly met. 

## 14 CFR 91.405(a), 91.407(a)**, 91.409 (a), 91.417 (a) &**  **(b) Maintenance Inspections** CellInfo, LLC believes that an exemption from there regulations is appropriate because the FAA has not developed maintenance standards that would allow an operator to meet the part 91 maintenance requirements. In particular, there are no individuals authorized by the FAA to approve a UAS for return to service under § 91.407(a). CellInfo, LLC will maintain the aircraft until it has reasonably determined that any needed repairs have been made. However, because of the technological impossibility of the meeting the requ irements of § 91.405(a), 407(a), 409(a), and 417(a)&(b), we believe exemption from these provisions is appropriate.**CellInfo** LLC Page **5**

CellInfo, LLC would like to safely operate a business that employs the utility of a UAS for inspections of cell tower infrastructure and p otential tower locations . A Section 333 exemption will give our business the necessary permissions to legally enter the NAS. Our safe and compliant operations will discourage illegal operations and assist in the proper solidification of the changing cell tower inspection industry

. Please do not hesitate to contact me at the phone number or email address provided above should you have any questions or concerns. Thank you for your consideration

. Sincerely, Victor Drouin President CellI nfo, LLC