TnT Video Services

Owners: Michael Thompson, Austin Thompson and Gabriel Thompson

2861 East County Road 1260

Plymouth, Illinois 62367

309-458-3267

U.S. Department of Transportation

Federal Aviation Administration

November 11, 2015

Re: Exemption request pursuant to Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) 

and (b); 14 CFR91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.109; 14 CFR 91.119(C); 14 CFR 91.121; 

14 CFR 91.151(a); 14 CFR91.203(a) and (b); 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)

Dear FAA Representative,

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and 

Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Michael Thompson, Austin 

Thompson and Gabriel Thompson, owners of TnT Video Services which owns and operates an 

Unmanned Aircraft System (UAS), hereby applies for an exemption from the listed Federal 

Aviation Regulations (FARs) to allow commercial operation of its 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.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and 

sensors, would operate in the following manner:

- Aerial photography and/or video for public and/or private use including real estate,

architecture, agriculture, surveying, engineering and other related professional activities.

- Aerial video and/or photography for public and/or private use including television, public

events, private events, cinematography and news gathering.

- Aerial inspection/photography of residential/commercial structures under contract with the

owners or local government authority.

- Aerial inspection/photography or residential/commercial utility infrastructure including but not

limited to electrical power lines, wind turbines and cell towers.

- Aerial video/photography or providing live video feed to assist with search and rescue

operations in cases of emergency or natural disaster only when the local authorities or

government has requested it by contract or donation.

-

TnT Video Services currently operates one Phantom 3 Professional (4) blade quad copter 

weighing 2.82 pounds or 1280 Grams. The UAS has a maximum airspeed of 16 miles per hour 

and uses a remote controller operating on frequency range of 2.400-2.483 GHZ. The Phantom 3 

Professional is equipped with built-in ground support technology that allows it to fly utilizing 

global positioning system (GPS) for stability, tracking, safe flight mode and a return-to-home 

feature in the event of loss of remote control signal or critical low battery.

All flights start with a pre-flight safety check and all flight data are recorded. The Phantom 3 

Professional is equipped with a gimbal mounted camera that sends a live video signal to the 

controller allowing the person in control (PIC) to monitor real-time video. Flight data, speed 

height, distance, battery level and general aircraft conditions are also displayed during operation. 

The Phantom 3 Professional battery has a flight time of 15-20 minutes and is, therefore, always 
returned to original takeoff point and always flown utilizing visual line of sight (VLOS). We have 

been training on the DJI Phantom 3 Professional for several months and have become proficient

in all aspects of flight and safety of this UAS. Our request for exemption would allow us to offer 

unique aerial photography and videography services to our clientele. We live in a very rural 

farming region and will make our services available to local law and fire services to assist in the 

search efforts for lost livestock or persons.

UAS Safety Operating Parameters

We will abide by the following additional operating conditions under this exemption, which 

ensures a level of safety during UAS flight including operating the UAS below 400 feed and 

within a radius of 1,000 feet from PIC always maintaining VLOS and obtaining permission from 

the owner/controller of any vessels, vehicles and structures when operations may be conducted 

closer than 500 feet to any such vessels, vehicles or structures. We will conduct a safety 

assessment of the risk of operating closer to those objects and determine that it does not present 

an undue hazard. Other safety operating parameters include:

- Operate the UAS for 15-20 minutes per flight.

- Land UAS prior to the manufacturers recommended minimum level of battery power.

- Operate the UAS during daylight hours only within VLOS.

- Utilize the UAS’ GPS flight safety feature whereby it hovers and then slowly lands if

 communication with the PIC is lost or battery becomes critically low.

- Always obtain all necessary permissions prior to operation.

- Have procedures in place to abort flights in the event of safety breaches or potential danger.

- Review weather reports prior to flight and never operate UAS in unsafe conditions, high wind,

 low clouds or conditions that hinder visibility.

- Only operate in safe environments that are strictly controlled, are away from power lines,

 elevated lights, airports and densely populated areas.

- Also conduct extensive preflight inspections and protocols during which safety carries primary

 importance.

The PIC will also have a minimum of five hours logged on this craft and 10 hours minimum 

flying UAS quad copters under varying conditions and environments and will follow all safety 

protocol as well as guidelines of 14 CFR §61.51(b) having the ability to safely operate the UAS 

in a manner consistent with the operating documents, including evasive and emergency 

maneuvers and maintaining appropriate distances from people.

Specific Exemptions Requested

Given the size, weight, speed and limited operating area associated with the UAS, we feel an 

exemption from 14 CFR Part 21, Subpart H (Airworthiness Certificates) and 14 CFR 91.203(a) 

and (b) (certifications required), subject to certain conditions and limitations, is warranted and 

meets the requirements for an equivalent level of safety under 14 CFR Part 11 and Section 333 of 

P.L. 112-95 (Section 333).

We request an exemption from 14 CFR 45.23 Marking of the Aircraft because the UAS will not 

have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, the twoinch lettering is difficult to place on such a small aircraft with dimensions smaller than the 

minimal lettering requirement. Regardless of this, we can mark the UAS in the largest possible 

lettering by placing the word “Experimental” on its fuselage as required by 14 CFR 45.29(f) so 

that anyone will see the markings.
We request an exemption from 14 CFR 61.113(a) and (b) Private Pilot Privileges and

Limitations: Pilot in Command. The applicant’s UAS do not carry any pilots or passengers nor 

property. The Risks attendant to the operation of the UAS is far less than the risk levels inherent 

in the commercial activities outlined in 14 CFR §61. The operation and limitations in the flight 

operation manual (FOM) will equate to the safe operations of the UAS.

We request an exemption from 14 CFR 91.7(a) which prohibits the operation of an aircraft 

without an airworthiness certificate, since there is currently no certificate applicable to our 

operation, this regulation is inapplicable. We request an exemption from 14 CFR 91.405(a), 14 

CFR 91.407(a)(1), 14 CFR 91.409(a)2) and 14 CFR 91.417(a) and (b) Maintenance inspections 

since they only apply to aircraft with an airworthiness certificate. However, as a safety 

precaution, we will perform a preflight inspection of the UAS before each flight as outlined in the 

attached operating documents.

We request an exemption from 14 CFR 91.9(b)(2) which requires an aircraft FOM in the aircraft,

however, since there are no pilots or passengers on board the aircraft, and given its size, this 

regulation is inapplicable. We believe an equivalent level of safety will be achieved by 

maintaining a safety/flight manual with the UAS ground station.

We request an exemption from 14 CFR 91.109 Flight Instruction: Simulated Instrument Flight 

and Certain Flight Tests. The regulation states that “no person may operate a civil aircraft that is 

being used for flight instruction unless that aircraft has fully functioning dual controls. Although 

the DJI Phantom 3 Professional is capable of dual/linked controls, ie. one operator controlling the 

flight path while another controls the camera movement, we will be operating with a single 

remote controller and a second technician as a spotter.

We request an exemption from 14 CFR 91.119(c) which prescribes safe altitudes for the 

operation of civil aircraft, but allows helicopters to be operated at lower altitudes in certain 

conditions. We will not operate our UAS above the altitude of 400 feet above ground level (AGL) 

and will also only operate in safe areas away from the public and traffic, thus “providing a level 

of safety at least equivalent to or below those in relation to minimum safe altitudes.” Given the 

size, weight and maneuverability and speed of the UAS, an equivalent or higher level of safety 

will be achieved.

We request an exemption from 14 CFR 91.121 Altimeter Settings, as it is inapplicable since the 

UAS utilizes electronic GPS with a barometric sensor. We request an exemption from 14 CFR 

91.151(a) Fuel Requirements for Flight in visual flight rules (VFR) conditions. The UAS is 100 

percent electric and two low battery alerts are issued – per the operating documents, the UAS will 

be landed at the first alert.

Also, our flights will last only 15-20 minutes each and the UAS has an automated function, which 

results in immediate landing when a low battery is detected. The PIC will not begin a flight 

unless, considering wind an forecast weather conditions, there is enough power to fly to the first 

point of intended landing and, assuming normal cruising speed, land the UAS with 30 percent 

battery power remaining.

Summary

We will comply with all of the following conditions and limitations should this grant of 

exemption be provided:

1. Operations will be limited to the following aircraft described in the operating documents which

is a quad-rotor aircraft weighing less than three pounds: DJI Phantom 3 Professional. 

2. The UAS will not be flown at an indicated airspeed exceeding 20 mph.

3. The UAS will be operated at an altitude of no more than 400 feet AGL, as indicated by the

procedures specified in the operating documents.
4. The UAS will be operated within VLOS of the PIC at all times.

5. All operations may utilize a visual observer (VO. The UAS will be operated within the VLOS 

of the VO at all times. The VO and PIC will be able to communicate verbally at all times. The 

PIC will be designated before the flight and will not transfer his or her designation for the 

duration of the flight. The PIC will ensure that the VO can perform the functions prescribed in the 

operating documents.

6. The operating documents will be accessible during the UAS operations and made available to

the Administrator upon request. Any revisions to the operating documents will be presented to

the Administrator upon request.

7. Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe flight. If 

the inspection reveals a condition that affects the safe operation of the UAS, the UAS will not be

operated until the necessary maintenance has been performed and the UAS is found to be in a

condition for safe flight. The Ground Control Station will be included in the preflight inspection.

All maintenance and alterations will be properly documents in the aircraft records.

8. Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g.

replacement of a flight critical component, will undergo a functional test flight. The PIC who

conducts the functional test flight will make an entry into the aircraft records.

9. The pre-flight inspection section in the operating documents will account for all discrepancies,

i.e. inoperable components, items or equipment not already covered in the relevant sections of

the operating documents.

10. We will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul,

replacement, inspection and life limit requirements.

11. We will carry out maintenance, inspections and record-keeping requirements, in accordance

with the operating documents. Maintenance, inspection and alterations will be noted in the

aircraft records, including total flight hours, description of work accomplished and the signature

of the authorized person returning the UAS to service.

12. Each UAS operated will comply with all manufacturer Safety Bulletins.

13. An authorized person will make an entry in the aircraft record of the corrective action taken

against discrepancies discovered between inspections.

14. The PIC will also meet the flight review requirements specified in 14 CFR 61.56 in an aircraft 

in which the PIC is rated on.

15. Prior to operations conducted for the purpose of aerial videography/cinematography and

augmenting real estate listing videos (or similar operations), the PIC will have accumulated and

logged, in a manner consistent with 14 CFR 61.51(b), a minimum of five hours as an UAS pilot

operating the make and model of the UAS to be used in operations.

16. The PIC will not operate the UAS for the purpose of aerial videography/cinematography and

augmenting real estate listing videos (or similar operations), unless the PIC has demonstrated

and logged in a manner consistent with 14 CFR 61.51(b), the ability to safely operate the UAS in

a manner consistent with the operating documents, including evasive and emergency maneuvers 

and maintaining appropriate distances from people, vessels, vehicles and structures.

17. UAS operations will not be conducted during night hours, as defined in 14 CFR 1.1 All 

operations will be conducted under visual meteorological conditions (VMC).

18. The UAS will not operate within five nautical miles of an airport reference point as denoted 

on a current FAA-published aeronautical chart.

19. The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than three statute miles from the PIC.

20. If a UAS loses communications or loses its GPS signal, it will return to a predetermined 

location within the planned operating area and land or be recovered in accordance with the 

operating documents.

21. The PIC will abort a flight in the event of unpredicted obstacles or emergencies in accordance

with the operating documents.
22. The PIC will not begin a flight unless, considering wind and forecast weather conditions, 

there is enough power to fly at a normal cruising speed to the intended landing point and land the 

UAS with 30 percent battery power remaining.

23. Before conducting operations, the radio frequency spectrum used for operation and control of

the UAS will comply with the Federal Communications Commission (FCC) or other appropriate

government oversight agency requirements.

24. The documents required under 14 CFR 91.9 and 14 CFR 91.203 would be available to the 

PIC at the Ground Control Station of the UAS at any time the UAS is operating. These

documents will be made available to the Administrator or any law enforcement official upon 

request.

25. The UAS will remain clear and yield the right of way to all manned aviation operations and

activities at all times.

26. The UAS will not be operated by the PIC from any moving device or vehicle.

27. The UAS will not be operated over congested or densely populated areas unless contracted 

out to do events.

28. Flight operations will be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from

the UAS and/or debris in the event of an accident. We will ensure that nonparticipating persons 

remain under such protection. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UAS, flight operations must cease immediately.

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller

of such vessels, vehicles or structures has granted permission and the PIC has made a

safety assessment of the risk of operating closer to those objects and determined that it

does not present an undue hazard.

c. Operations near to the PIC, VO, operator trainees or essential persons do not present an

undue hazard to those persons per 14 CFR 91.119(a).

29. All operations will be conducted over private or controlled-access property with permission

from the land owner/controller or authorized representative. Permission from land

owner/controller or authorized representative will be obtained for each flight to be conducted.

30. Any incident, accident or flight operation that transgresses the lateral or vertical boundaries of

the operational area as defined by the applicable certificate of authorization (COA) will be

reported to the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents will be

reported to the National Transportation Safety Board (NTSB) per instructions contained on the

NTSB website: www.ntsb.gov.

On behalf of TnT Video Services, I would like to thank you for your consideration in granting 

this exemption.

Signed,

Michael Thompson

TnT Video Services