INNOVATIVE TOWER SOLUTIONS LLC

EXEMPTION REQUEST Section 333 of the FAA Modernization & Reform Act and 14 CFR §11

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### INNOVATIVE TOWER SOLUTIONS LLC

PO BOX 213
ELBERFELD IN 47613

304

- 906

- 5628 July 2 3 , 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave SE Washington, D

. C

. 20590

RE: EXEMPTION REQUEST
Section 333 of the FAA Modernization & Reform Act

14 CFR §11

Dear Sir or Madam:

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

14 CFR Part 11, Innovative Tower Solutions LLC, hereafter referred to as ITS LLC

, operator of

s mall

, Unmanned A erial Vehicles ( UA Vs ) equipped to conduct aerial videography

, cinematography, photography and inspection s , hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to all ow commercial operation of its UAVs, so long as such operations are conducted wi thin and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

The requested exemption would permit the commercial operation of small, unmanne d and relatively inexpensive UAVs under controlled conditions in ai rspace that is 1) limited, 2) predetermined, 3) controlled as to access and 4) would provide safety enhancements to the already safe operations using conventional aircraft . Approval of this exemption would thereby enhance safety and fulfill the Secretary o f Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.”

NAME AND ADDRESS OF THE APPLICANT

Innovative Tower Solutions LLC ATTN: Joseph G. Dumas

PO Box 213 Elberfeld, IN 47613

Joseph G. Dumas

304

- 906

- 5628

inntowsol@outlook.comINNOVATIVE TOWER SOLUTIONS LLC

EXEMPTION REQUEST Section 333 of the FAA Modernization & Reform Act and 14 CFR §11

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### INNOVATIVE TOWER SOLUTIONS LLC

PO BOX 213
ELBERFELD IN 47613

304

- 906

- 5628 This exemption application is expressly submitted to fulfill Congress’ goal in passing Section

333 (a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 33 3 of the Reform

Act. I n making this determination, the Secretary is required to determine which types of UA V do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

• The UA V size, weight, spe ed, and operational ca pability

• Operation of the UA V in close proximity to Airports, Power Plants, Fuel Depots and populated areas

• Operation of the UA V within visual line of sight of the operator

Reform Act §333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. §333(c) (emphasis added) 1

. The Federal Aviation Act expressly grants the FAA the author ity to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, which includes UA V , from the requirement that all civil aircraft must have a

cur rent airworthiness certificate

. The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702

- 44716 of this title if the Administrator finds the exempti on in the public interest. 49 US C. §44701(f ) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

ITS LLC operates multi rotor UAVs , weighing less than 30 pounds including payload. They operate under normal conditions at a maximum speed less than 50 mph, have the ability to hover

, and move in the vertical and horizontal plane simultaneously . The applicable specifications for

the UAV models utilized by ITS LLC are as follows in Table 1 . All UAVs are only operated in line of sight and within the area specified by the consumer and/or approved by the property owner, when applicable. Such operations will insure that the UAVs will “not cr eate a hazard to users of the national airspace system or to the public.

1 Applicant interprets this provision to place the duty on the Administrator to not only process applications for exemptions und er §3 33, but for the Administrator to craft conditions for the safe operation of the UAS, if it should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval.INNOVATIVE TOWER SOLUTIONS LLC

EXEMPTION REQUEST Section 333 of the FAA Modernization & Reform Act and 14 CFR §11

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### INNOVATIVE TOWER SOLUTIONS LLC

PO BOX 213
ELBERFELD IN 47613

304

- 906

- 5628 Table 1: ITS LLC UAV Specifications 2

INSPIRE 1 IRIS + PHANTOM 2 X8

MANUFACTURER DJI 3DRobotics DJI 3DRobotics

PROPELLERS 4 4 4 8

DIMENSIONS 17.3” x 17.8” x 11.9” 4.3” x 21.7” 13.7” x 8” 3 13.7” x 20.1” x 1.4”

WEIGHT WITH BATTERY 6.5 lbs. 2.8 lbs. 2.2 lbs. 5.6 lbs.

PAYLOAD CAPACITY N/A 0.8 lbs. 0.7 lbs. 1 .7 lbs.

ONBOARD CAMERA X3 N/A N/A N/A

RADIO RANGE 1.2 miles 0.6 miles 0.62 miles 0.2 miles; geofence enabled
0.62 miles; geofence disabled

FLIGHT TIME ≤ 18 minutes 16

- 22 minutes 25 minutes 4 ≤ 15 minutes

MAXIMUM SPEED 49.2 mph NOT AVAILABLE 5 33.6 mph NOT AVAILABLE 6

MAXIMUM ALTITUDE 2.8 miles NOT AVAILABLE 7 0.07 miles 8 0.06 miles; geofence enabled

POWER SOURCE Battery Battery Battery Battery

2 All weights and measures have been converted to Imperial for reviewer convenience

3 http://www.dji.com/product/phantom

- 2/spec

4 http://www.dji.com/product/phantom

- 2/spec

5 Request for this information ha s been submitted to the manufacturer. ITS LLC will monitor and ensure UAV speed is maintained at or below 50 mph.

6 Request for this information has been submitted to the manufacturer. ITS LLC will monitor and ensure UAV speed is maintained at or below 50 mph.

7 Request for this information has been submitted to the manufacturer. ITS LLC will monitor and ensure UAV altitude is maintained at or below 400 feet.

8 Phantom 2 DashboardINNOVATIVE TOWER SOLUTIONS LLC

EXEMPTION REQUEST Section 333 of the FAA Modernization & Reform Act and 14 CFR §11

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### INNOVATIVE TOWER SOLUTIONS LLC

PO BOX 213
ELBERFELD IN 47613

304

- 906

- 5628 Given the small size of the UAVs involved and the restrictive environment within which they will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UAVs to commence immediately. Also due to the size of the UAVs and the restricted areas in which the relevant UAVs will operate, approval of the application presents no national security issue. Given the clear direction in §3 33 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impa cts, including reduced emissions associated with allowing UAVs for aerial videography, cinematography, photography and inspection s , the grant of the requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the

F AA grant the requested exemption without delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. Th ese limitations provide for at least an equivalent or higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to aerial videography, cinematography, photography and inspecti on s conducted with conventional aircraft.

These limitations and conditions to which Innovative Tower Solutions LLC agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1. The UAVs will weigh less than 30 pounds

. 2. Flights will be operated within line of sight of the UAV pilot and/or visual observer.

3. Maximum total flight time for each operational flight will be between 10 and 20 minutes dependent on which UAV is in operation (See Ta ble 1, Flight Time ). Flights will be terminated at 25% battery power reserve should that occur prior to the manufacturers estimated UAV flight time.

4. Flights will be operated at an altitude of no more than 400 feet AGL or not more than

200 feet above an ele vated platform from which filming is planned.

5. Minimum crew for each operation will consist of the UAV pilot and visual observer.

6. The UAV pilot will be Pilot in Command ( PIC ) or operate under the guidance and oversight of a pilot certificate holder.

7. The PIC will hold an airline transport, commercial, private, recreational, or sport pilot

certificate and a current FAA airman medical certificate or a valid U.S. driver’s license

. 8. The UAV will only operate within a confined area of operation as de fined by the consumer and/or approved by the property owner, when applicable.INNOVATIVE TOWER SOLUTIONS LLC

EXEMPTION REQUEST Section 333 of the FAA Modernization & Reform Act and 14 CFR §11

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### INNOVATIVE TOWER SOLUTIONS LLC

PO BOX 213
ELBERFELD IN 47613

304

- 906

- 5628 9. A briefing will be conducted in regard to the planned UAV operations prior to each production activity. It will be mandatory that all person nel who will be performing

duties within the b oun daries of the area of operation be present for this briefing.

10. The operator will file a FAA form 7711

- 1, or its equivalent, as modified in light of the requested exemption, with the appropriate Flight Standards District Office (FSDO).

11. The operator will o btain the consent of all persons involved in the filming and ensure that only consenting persons will be allowed within 100 feet of the flight operation . T his radius may be reduced based upon an equivalent level of safety and, with advanced permission of t he relevant FSDO, operations at closer range can be approved.

12. The operator will submit a written Plan of Activities to the FSDO three days before the proposed shoot.

13. All ITS LLC crew will be trained in operation of the UAVs ( Table 1 ) generally and will receive up

- to

- date information on the particular UAV to be operated.

14. Visual observer and UAV pilot will at all times be in voice communication range.

15. Written and/or oral permission for the relevant property holders will be o btained.

16. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire or other appropriate governmental agencies.

17. If the UAV in operation loses communication or its GPS s ignal, the UAV will have capability to return to a pre

- determined location within the security perimeter and land.

18. The UAV in operation will have the capability to abort flight in case of unpredicted obstacles or emergencies.

14 CFR § 21 ( H ): AIRWORTHINESS CERTIFICATES 14 CFR §91.203 (a) (1)

ITS LLC seeks an exemption from 14 CFR §21 (H) which requires the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area

associated with the aircraft to be ut ilized by ITS LLC, an exemption from Part 21, Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 USC §44701 (f)) and Section 333 of the Reform Act

both authorize t he FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports, power plants, fuel depots and populated areas of the particular UAV. In all c ases, an analysis of these criteria demonstrates that the UAV operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rot orcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.INNOVATIVE TOWER SOLUTIONS LLC

EXEMPTION REQUEST Section 333 of the FAA Modernization & Reform Act and 14 CFR §11

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### INNOVATIVE TOWER SOLUTIONS LLC

PO BOX 213
ELBERFELD IN 47613

304

- 906

- 5628 The UAVs to be operated hereunder are each less than 30 lbs. fully loaded, carry neither a pilot nor passenger, carry no explosive materials or flammable liquid fuels and operate exclu sively within a secured area as defined by the consumer and/or approved by the property owner, when applicable. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the UAV operator and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation as is now done with conventional filming. The FAA will have advance notice of all operations. These safety

enhan cements, which already apply to civil aircraft operated in connection with video production, provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under

14 CFR Par t 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAVs, due to their sizes, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load ( Table 1 ). Accordingly, an exemption will be required for the airworthiness certificates requirements of 14 CFR §21 (H).

14 CFR §45.23 (b): MARKING OF THE AIRCRAF T

ITS LLC seeks an exemption from 14 CFR §45.23 which requires w hen marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

sport category aircraft or experimental or provisionally certificat ed aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “pr ovisional,” as applicable.

Even though each UAV will have no airworthiness certificate, an exemption may be needed as the UAV will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the UAV, two

- inch lettering will be impossible. The word “Experimental” will be placed on the fuselage of each UAV in compliance with §45.29 (f).

The equivalent level of safety will be provided by having each UAV marked on its fuselage as required by §45.29 (f) where the UAV pilot, visual observer and others working with the UAV will see the identification of the UAV as “Experimental.” The FAA has p reviously approved exemptions for Marking of the Aircraft in this manner. 9 Accordingly, an exemption will be required for the marking of the aircraft requirements of 14 CFR §45.23

9 Exemptions Nos. 10700, 8738, 10167, 10167A and 11284INNOVATIVE TOWER SOLUTIONS LLC

EXEMPTION REQUEST Section 333 of the FAA Modernization & Reform Act and 14 CFR §11

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### INNOVATIVE TOWER SOLUTIONS LLC

PO BOX 213
ELBERFELD IN 47613

304

- 906

- 5628 14 CFR §61.113 (a) and (b): PRIVATE PILOT PRIVILEGES AND LIMITATIONS:
PILOT IN COMMAND

ITS LLC seeks an exemption from 14 CFR § 61.113 (a) and (b) which limit s private pilots to

non

- commercial operations. Because the UAVs will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of cur rent operations by requiring the UAV operator to be, or operate under the supervision of, a private pilot’s license holder rather than a commercial pilot’s license holder. Unlike a conventional aircraft that carries the pilot and passengers, the UAVs are r emotely controlled with no living entity on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance. The level of safety provided exceeds that provided by a single individual holding a commercial pi lot’s certificate operating a conventional aircraft. The risks associated with the operation of the UAVs are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the UA Vs as requested with a private pilot as UAV operator

, or in a supervisory role aiding the UAV operator , exceeds the present level of safety achieved by 14 CFR §61.133 (a) and (b). Accordingly, an exemption will be required for the private pilot privileges and limitations: pilot in command requirements of

14 CFR §61.113 (a) and (b).

14 CFR §91.7 (a): CIVIL AIRCRAFT AIRWORTHINESS

ITS LLC seeks an exemption from 14 CFR §91.7 (a) which requires that no person may operate

a civil aircraft unless it is in airwort hy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft, UAV maintenance and pre

- flight

safet y check, an equivalent level of safety will be provided. Accordingly, an exemption will be required for the civil aircraft airworthiness requirements of 14 CFR § 91.7 (a).

14 CFR §91.9 (b) (2): CIVIL AIRCRAFT FLIGHT MANUAL IN THE AIRCRAFT

ITS LLC seeks an e xemption from 14 CFR §919 (b) (2) which requires n o person may operate a
U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current ap proved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any

combination thereof.

The UAVs, given their size and configuration, have no ability or place to carry such a flight manual on the aircraft, not only becaus e there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft.INNOVATIVE TOWER SOLUTIONS LLC

EXEMPTION REQUEST Section 333 of the FAA Modernization & Reform Act and 14 CFR §11

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### INNOVATIVE TOWER SOLUTIONS LLC

PO BOX 213
ELBERFELD IN 47613

304

- 906

- 5628 The equivalent level of safety will be maintained by keeping the flight manual for the UAV in operation at the ground control point where the UAV operator will have immediate access to it.

The FAA has approved a multitude of exemptions for Civil Aircraft Flight Manual In The

Aircraft. 10 Accordingly, an exemption will be required for the civil aircraft flight manual in the aircraft requirements of 14 CFR §91.9 (b) (2).

14 CFR §91.103: PREFLIGHT ACTION

ITS LLC seeks an exemption from 14 CFR §91.103 , which requires a PIC to become familiar with specific information before each flight, including information contained in the FAA

approved Flight Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely conduct the flight, an exemption is requested to the extent that an FAA

approved Flight Manual is required.

An equivalent level of safety will be provide d by following the in use UAV User Guide and/or Operation Manual . The PIC wil l identify any d efects or inoperable components including Pre

Flight, Launch, Landing, and Post

- Flight checks . The PIC will also review weather, flight requirements, battery charg e, landing and takeoff distance, UA V performance data, and contingency landing areas before initiation of flight . The in operation UAV Users Guide will be kept at the Ground Control Station and will be accessible to the PIC at all times while operating

the in use UA V. Accordingly, an exemption will be required for the preflight action requirements

of 14 CFR §91.103.

14 CFR §91.109 : FLIGHT INSTRUCTION

ITS LLC seek s an exemption from 14 CFR §91.109 (a) , which provides in pertinent part that "[n]o person may o perate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls." UAVs and remotely piloted aircraft, by their design, do not have functional dual controls. Flight co ntrol is accomplished through the use of a device that communicates with the airc raft via radio

communications.

The equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and s peed of the aircraft. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. 11 Accordingly, an exemption will be required for the flight instru ction requirements of 14 CFR §91.109 (a).

10 Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, 10700 and 11284

11 Exemption Nos. 5778K, 9862A and 11284INNOVATIVE TOWER SOLUTIONS LLC

EXEMPTION REQUEST Section 333 of the FAA Modernization & Reform Act and 14 CFR §11

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### INNOVATIVE TOWER SOLUTIONS LLC

PO BOX 213
ELBERFELD IN 47613

304

- 906

- 5628 14 CFR §91.119: MINIMUM SAFE ALTITUDES

ITS LLC seeks an exemption from the minimum safe altitude requirements of 14 CFR §91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may not ope rate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure in

non

- congested areas ( 14 CFR §91.119 (c) ) . Section 91.119 (d) allows for a helicopter to operate at less than those minimum altitudes when it can be opera ted "without hazard to persons or property on the surface," provided that "each person operating the helicopter complies with any routes or altitudes specifically prescrib ed for helicopters by the FAA."

An exemption is required because in order to perform the intended filming, the UA V must operate not more than 400 feet AGL or 200 feet above an elevated platform from which filming is planned . Further, it will be operated in a restricted area where buildings and people will not be exposed to operations witho ut their pre

- obtained notification and consent, when required.

The equivalent level of safety will be achieved given the size, weight, UAV speed and location of operation. No flight will be taken without the permission of the consumer and property owner

an d/or local officials, as applicable. All affected individuals will be notified in advance and aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 30 lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL in the video production industry. In addition, the low

- altitude o perations of the UAV will ensure separation between the small UAV operations and the operations of conventional aircraft that must comply with §99.119. Accordingly, an exemption will be required for the minimum safe altitude requirements of

14 CFR 91.119

1 4 CFR §91.121: ALTIMETER SETTING

ITS LLC seeks an exemption from 14 CFR §91.121 which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport o r barometric pressure. UA V s do not have a barometric altimeter, but

rather a GPS altitude read out. An equivalent level of safety will be achieved by the UAV operator confirming the altitude of the launch site shown on the GPS altitude indicator before

fli ght. Accordingly, an exemption will be required for the altimeter setting requirements of

14 CFR 91.121.INNOVATIVE TOWER SOLUTIONS LLC

EXEMPTION REQUEST Section 333 of the FAA Modernization & Reform Act and 14 CFR §11

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### INNOVATIVE TOWER SOLUTIONS LLC

PO BOX 213
ELBERFELD IN 47613

304

- 906

- 5628 14 CFR §91.151 (a): FUEL REQUIREMENTS FOR FLIGHT IN VFR CONDITIONS

ITS LLC seeks an exemption from 14 CFR §91.151 (a) which prohibits an individual from beginning a flight in an airplane 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

– (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The FAA has stated that an equivalent level of safety can be achieved by requiring that each UAV operation be completed within 30 minutes flight time or with 20% ba ttery power remaining, whichever occurs first. 12 ITS LLC conforms to this limitation, and therefore provides an equivalent level of safety.

The UAVs utilized by ITS LLC each include a low battery warning system. The amount of battery reserve power remainin g is transmitted to the UAV operator via telemetric data feed from the UAV to a ground

- based

- on

- screen display or via visual indicators on the UAV. The UAV operator will promptly fly the UAV back to the pre

- determined landing location or abort location

whe re the UAV may safely land, while still maintaining a minimum of 2 5 % reserve battery power. All UAV flights will be safely terminated when the batteries fall below 25 % capacity, combined with the requirement that flights only be conducted within a secure, isolated area, using a UAV weighting less than 30 pounds , and within visual line of sight of the UAV operator and/or visual observer, ensure that the proposed operation will provide an equivalent or higher level of safety to that provided by the regulation s from which exemption is sought.

No meaningful flight operations can be conducted while still maintaining a 30

- minute battery reserve due to the technological limitations on UAV battery power. Similar exemptions have been granted to other operations. 13 Acc ordingly, an exemption will be required for the fuel requirements for flight in VFR conditions requirements of 14 CFR 91.151 (a).

14 CFR §91.203 (a) and (b): CARRYING CIVIL AIRCRAFT CERTIFICATION AND
REGISTRATION

ITS LLC seeks an exemption from 14 CFR §91. 203 which requires

, (a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate... (b) No person may operate a civil aircraft

unless the airworthine ss certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

12 Grant of Exemption to Clayco, Inc ., Federal Register Number: 2014

- 19457, Docket No. FAA

- 2014

- 0507

13 Exemption Nos 2689F, 5745, 10673, 10808 and 11284INNOVATIVE TOWER SOLUTIONS LLC

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### INNOVATIVE TOWER SOLUTIONS LLC

PO BOX 213
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304

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- 5628 Each UAV utilized by ITS LLC when fully loaded weigh s no more than 30 lbs. and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the UAV. An equivalent level of safety will be achieved by keeping these document s at the ground control point where the UAV operator will have immediate access to them, to the extent they are applicable to the UAV. The FAA has issued numerous exemptions to this regulation. 14 Accordingly, an exemption will be required for the carrying c ivil aircraft certification and registration requirements of

14 CFR §91.203 (a) and (b).

14 CFR §91.405 (a ), §91. 407 (a) (1), §91.409 (a) (2), and §91.417 (a) and (b):
MAINTENANCE INSPECTIONS

ITS LLC seeks an exemption from the maintenance inspection requi rements contained in

14 CFR § 91.405 (a), 91.407 (a) (1), 91.409 (a) (2); 91.417 (a) and (b). These regulations specify maintenance and inspection standards in reference to 14 CFR Part 43. 14 CFR § 91.405 (a) stat es that each owner or operator of an aircraft "[s]hall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections ...have discrepancies repaired as prescribed in part 43 of this chapter"

. Part 43 and these sections only apply to aircraft with an

airworthi ness certificate, which the UA Vs to be operated by ITS LLC will not have. Maintenance will be accomplished by the UAV operator pursuant to each UAVs user manual and/or operator manual. An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the m anuals for each UAV and any required manufacturer Safety or Service Bulletins . T he PIC will conduct a pre

- flight inspection of the

UA V to be utilized and all associated equipment to account for all discrepancies and/or inoperable components. Maintenance will be performed and verified to address any conditions potentially affecting safe operation of the UA V and no flights will occur un less, and until

, all flight critical components of the UA V have been found to be airworthy and in a condition safe for operation. A functional test flight will be conducted following the replacement of any flight

critical components. Accordingly, an exempt ion will be required for the maintenance inspection requirements of 14 CFR § 91.405 (a), 91.407 (a) (1), 91.409 (a) (2); 91.417 (a) and (b)

.

FEDERAL REGISTER SUMMARY

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the FEDERA L REGISTER, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal Regulations:

14 Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, 107 00 and11284INNOVATIVE TOWER SOLUTIONS LLC

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PO BOX 213
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- 5628 14 CFR §21, Subpart H ; 14 CFR §45.23(b) ; 14 CFR §61.113 (a) and (b) ; 14 CFR §91.7 (a); § 91.9 (b); §91.103 (b); §91.109; §91.119; §91.121; §91.151 (a); §91 .103 (a) and (b) ; §91.405 (a); §91.407 (a); §91.409 (a) (1); §91.409 (a) (2); §91.417 (a) and (b) to operate commercially a small UAV ( 30 lbs. or less) in aerial videography, cinematography, photography and inspections operation.

The exemption will enhance safety by reducing risk to the general public and property owners from the substantial hazards associated with performing equivalent film work with conventional

fixed

- wing aircraft, rotorcr aft, or other methods

.

CONCLUSION

All ITS LLC flights will occur within a confined area of operation as defined by the consumer and/or approved by the property owner, when applicable. Filming will limited to people who have provided c onsent to be filmed or have otherwise agreed to be in the area of flight operation and filming.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

- size, weight, speed, operating capabilities, proximity to airports and populated areas, operation with in visual line of sight and national security

- provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of the petitioners UAVs for aerial videography, cinematography, photography and inspections

.

Tha nk You,

Joseph G. Dumas

Owner

Innovative Tower Solutions LLC

304

- 906

- 5628

ATTACHMENTS:

• Inspire 1 User Manual

• IRIS + Operation Manual

• Phantom 2 User Manual

• X8 Operation Manual