28 August, 2015

From: 

Travis J Dziubla

945 Ohlone Ave, #963

Albany, CA 94706

(858) 353-2556

tdziubla@gmail.com

AMA Member: 1075199

FCC Callsign KK6TZN

Subject:

Petition for Exemption 14 CFR § 11.81, Exemption petition under 14 CFR section 21 (§§

21.171 - 21.199) and SEC 333 of THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

The specific section or sections of 14 CFR from which you seek an exemption:

1. I petition for exemption from 14 CFR section 21; specifically SUBPART H — Airworthiness

Certificates (§§ 21.171 - 21.199) as required for UAS operations for Civil Aircraft.

2. I also petition for Exemption under Sec 333 of THE FAA MODERNIZATION AND REFORM 

ACT OF 2012 (PUBLIC LAW 112-95)

The extent of relief you seek and the reason you seek the relief:

Current FAA rules prohibit the use of a UAS for commercial purposes on private property and 

UAS operations or Civil Aircraft without obtaining an FAA Airworthiness Certificate. I am seeking 

relief of these requirements, including obtaining an FAA Airworthiness Certificate. I am an 

experienced UAS pilot and am simply petitioning for an exemption to provide a commercial 

service to private land owners and companies who wish to obtain and capture Aerial photosand 

videos of said property for purposes including, but not limited to: 

(1) real estate listings

(2) insurance property claims, and 

(3) as a marketing tool for businesses

I would like to seek an exemption for the purposes of rendering the above services in a 

commercial setting, allowing me to set the foundation for a small business in the future while 

also legally serving the community with a highly sought-after service.
How your request would benefit the public as awhole:

The Section 333 Exemption process provides operators who wish to pursue safe and legal entry

into the NAS a competitive advantage in the UAS marketplace, thus discouraging illegal

operations and improving safety. It is anticipated that this activity will result in significant

economic benefits, and the FAA Administrator has identified this as a high priority project to

address demand for civil operation of UAS for commercial purposes.

As noted above, the public sector currently places a high demand on UAS services for 

commercial purposes. My exemption would benefit the public by providing customers with:

(1) a legally exempt pilot with 15 years of recreational UAS experience

(2) a platform for small business to grow and expand their operations

(3) a positive example of responsible UAS operation, thereby educating the public on safe use

By allowing me to serve my community with the requested exemption, we could begin to curb 

the reckless and illegal use of commercial UAS by inexperienced operators, who are currently 

serving a community that has been historically underserved in aerial photography.
Reasons why the exemption would not adversely affect safety, or how the exemption would 

provide a level of safety at least equal to the existing rule:

As a 15 year UAS veteran, former military officer, and licensed HAM operator, I have an 

understanding and appreciation for potential risk to the safety of the public, therefore, I would

be a good candidate for exemption of 14 CFR section 21 (§§ 21.171 - 21.199) and SEC 333 

while not putting Air Safety in any additionalrisk.

The UAS I employ (a customized system based on the TBS Discovery Pro) and for which I am

seeking exemption for has been built with numerous redundant safety features, including SAFE 

technology, GPS navigation, and automatic Return to Launch features. When flying forthis 

commercial purpose I would be flying at a maximum altitude of 200’, greater than 5 miles from 

any airport, and away from any people beyond myself (as PIC) and my safety observer (SO). My 

service in the Navy as an Air Safety/Maintenance Officer also means I understand the inherent 

risks, and required mitigation techniques, to ensure proper aircraft operation. I wouldnot be 

flying near disaster areas, sporting events, or high traffic areas including airports and freeways, 

andI would pay attention to NOTAMs in order to ensure consistent compliance.

Furthermore, all my UAS are custom designed and built by myself, meaning I fully understand 

the aeronautical/electrical engineering required to operate UAS, as well as the physical and 

operational abilities and limitations of the systems I employ. This means that the public can be 

assured that no system will fail for lack of knowledge or understanding of the systems I employ.

My airframe uses the NAZA 2 Flight Controller, and as such I will be flying primarily in Mode 1: 

Flight Mode – GPS Attitude Mode (Default) I

This mode allows the UAS to lock on a home GPS position as a failsafe to prevent loss of radio 

control of the UAS due to unwanted interference or loss of power. Also includes built in no-fly 

zones to restrict flight over airports, and other sensitive locations.

Please see Enclosure 2 for a flight safety checklist that I will utilize pre-launch and post-recovery 

to ensure full compliance, as well as my SO guidelines to be reviewed prior to every flight.
A summary we can publish in the Federal Register—

I, Travis J. Dziubla, am seeking an exemption of 14 CFR section 21 (§§ 21.171 - 21.199) and

Section 333 of THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95) 

rules. I am petitioning for an exemption to provide a commercial service to private land owners 

and companies who wishto obtain and capture aerial photography and videos of their property 

for purposes of realestate listings, insurance property claims, and for marketing of businesses. 

Asa 15 year UAS veteran pilot, former military Air Safety/Maintenance officer, and licensed 

HAM radio operator, I have a thorough understanding and appreciation for potential risk to the 

safety of the public when operating UAS. With these qualifications in mind, I would be a strong

candidate for exemption in order to better serve the public.

The UAS I employ (a customized system based on the TBS Discovery Pro) and for which I am

seeking exemption for has been built with numerous redundant safety features, including SAFE 

technology, GPS navigation, and automatic Return to Launch features. When flying forthis 

commercial purpose I would be flying at a maximum altitude of 200’, greater than 5 miles from 

any airport, and away from any people beyond myself (as PIC) and my safety observer (SO). My 

service in the Navy as an Air Safety/Maintenance Officer also means I understand the inherent 

risks, and required mitigation techniques, to ensure proper aircraft operation. I wouldnot be 

flying near disaster areas, sporting events, or high traffic areas including airports and freeways, 

andI would pay attention to NOTAMs in order to ensure consistent compliance.

I appreciate the FAA’s consideration of this petition for exemption.
Any additional information, views, or arguments available to support your request:

I intend to use the safety checklist in enclosure 2 to ensure 100% compliance with FAA 

requirements, AMA guidelines, and insurance purposes.

If you want to exercise the privileges of your exemption outside the United States, youmust 

state the reason.

I have no intention of using this exemption outside the United States
Exhibit 1: UAS Specifications

UAS

Airframe TBS Discovery Pro

Motors: Turnigy 1000kV motors

Propellers: Graupner e-Prop 9x3

Flight Controller: DJI Naza V2 + GPS

Battery: TBS 4s 4500mAH

VTx: Lumenier 600mW 5.8GHz

Rx: FrSky X8R 16ch

Tx: FrSky Taranis Plus+

Voltage Monitor: FrSky SmartPort LiPo Voltage Sensor

Max Weight at takeoff: 5.3lbs

Max Speed: 60MPH

Max Altitude: limited in Flight Computer to 200’

Max Range: Tested safely to 45db, 1mi (VLOS ends at 1mi)

Ground Station

Custom design, Immersion RC Duo 5800 VRx with -7dB Patch and -3dB RD antennas
Enclosure 2: Flight Safety Checklist

Maintenance (checked day prior) PIC Checked SO Checked Date Notes

Nuts and screws tightened N/A

Voltage monitors calibrated N/A

Blades balanced and free of damage N/A

Camera lens cleaned, card cleared N/A

Gimbal calibrated N/A

Compass calibrated N/A

GPS calibrated N/A

All batteries charged and stored safely N/A Batt 1: Batt 2: Batt 3:

Fail-safe and ABORT conditions tested on Tx, Rx N/A

SAFE boundaries updated and verified N/A Local airports? 200' ceiling?

Flight and Site conditions PIC Checked SO Checked Date Notes

Check map for nearest airport How far is nearest airport? Which direction?

Check for updated NOTAM What is date of last NOTAM?

Site walked, obstructions noted, secondary landing chosen What obstructions exist? Where is secondary landing point?

Nearest people to flight path

Nearby residents or concerned parties addressed

Primary launch and landing sites cleared of debris

SO briefed, flight plan understood by all parties

Ground Station Checks PIC Checked SO Checked Date Notes

Battery voltage readout at 12.2-12.6V N/A

VRx signal path interruption checks satisfactory N/A

Tx checks complete; model selected, battery >75% N/A

RSSI response testing completed satisfactory N/A

Vehicle Pre-Launch PIC Checked SO Checked Date Notes

Blades tight and secure N/A

Battery voltages checked N/A C1: C2: C3: C4: 

Secondary Camera secured, power on, signal good N/A

Pilot camera lens removed, signal good N/A

GPS lock (In mode 1, double blinking green lights on FC)

Launch site clear 10' in all directions

No personnel in front of flight line

ABORT FLIGHT CONDITIONS

Personnel entering the flight area

Unexpected loss of video signal

Unexpected receipt of RSSI <45DB

Individual cell voltage <3.6

Total cell voltage <14.8V

Total mAH discharged >3500