ENGINEERING 

### U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue, S.E. West Building Ground Floor, Room W 12-140

Washington, DC 20590



## RE: Petition for Exemption under Section 333 of the FAA Modernization and Reform Act and Part 11.81 of the Federal Aviation Regulations.
September 8, 2015

Petitioner: TGC Engineering, LLC Jeremy M. Sack, P.S., Project Manager 1310 Sharon Copley Road PO BOX 37 Sharon Center, Ohio 44274 Phone: (330) 590-8004 ext. 707 Email: jsack a,tg-cen in

g eerint .com Website: www.tgcen in

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### eering, com

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11.81, TGC Engineering, LLC hereby applies for an exemption from the listed Federal Aviation Regulations (FAR's) to allow commercial operation of its small, unmanned aircraft for photogrammetry, surveying, inspection and analyses. All operations shall be conducted within and under the conditions and limitations outlined previously by the FAA as required by Section 333 and conducted in compliance with the attached On-Site Safety checklist and User Manual.
1. Sections from which TGC Engineering, LLC requests exemptions to the extent necessary to conduct the operation categories listed above:

a. 14 CFR Part 21, subpart H b. 14 CFR Part 61.113 (a) and (b) c. 14 CFR Part 91:

i. 91.103 (b)(2) ii. 91.105 iii. 91.109 iv. 91.119 v. 91.121 vi. 91.151 vii. 91.405 viii. 91.407 ix. 91.409 0 

### O TGC ENGINEERING + 1310 SHARON COPLEY RD + P.O. BOX 37 + SHARON CENTER, OH 44274

P + 330.590.8004 TGCENGINEERING.COM F + 888.820.8423 TCRANE@TGCENGINEERING.COM

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### Relief Sought: x. 91.416

a. TGC Engineering, LLC desires to operate small Unmanned Aircraft Systems (sUAS) for commercial purposes to include (but not be limited to) Photogrammetry, Topographic Surveying, Industrial/Civil Infrastructure Inspections and analyses. This relief is sought because the law currently prohibits commercial use of sUAS unless performed under an exemption.
b. This exemption will cover the use of the following airframes, all of which weigh less than 55 pounds including payload and energy source (takeoff weight):
i. DJI Phantom 3 Professional. (see attached DJI Phantom 3 Professional User Manual) ii. Other models to be added by future amendment to this exemption.
3. Public Benefit

a. Use of sUAS technology to obtain imagery, information and data currently obtained by use of manned flight or manual methods: i. Reduces statistical risk to human life due to manned aircraft accidents (e.g., infrastructure inspections) and due to other high risk activities that can be avoided (e.g., cell towers, transmission towers, multistory buildings, roadway bridges, etc.) ii. Reduces the cost associated with the collection of such information listed above which benefits the customers and improves to the overall economy. iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions from manned aircraft and ground-based vehicles.
4. Safetv not Adverselv Affected

a. Aircraft will be registered and marked in accordance with Section 44711 and Part 45, Subpart C.
b. Aircraft will comply with maintenance and inspection requirements of the manufacturer (DJI). AII repair and maintenance work will be conducted or approved by qualified personnel such as those of Advexure (or equivalent), and will require a test flight after such work. Records of all maintenance and repair work will be kept in a maintenance log for each aircraft. See Attached Exhibit C.

c. AII flight operations will be conducted by at least two individuals (PIC and Observer) who will verbal communication capability with each other at all times during the flight, and who will remain stationary on the ground during the flight operations: i. A Pilot in Command (PIC) who posses the following credentials: 1. An Airman Certification issued under 14 CFR 61 (Private Pilot License) screened by the TSA. 2. Third Class medical certificate issued under 14 CFR 67. 3. A Bi-annual flight review issued under 14 CFR 61.56. 4. Successful completion of a UAS knowledge test in a specified form. 5. At least 200 cycles and 25 hours of flight experience in a UAS rotorcraft (or UAS fixed-wing in the case of fixed wing flight operations under this exemption). Such cycles and hours may be gained during flights under this


### TGC ENGINEERING + 1310 SHARON COPLEY RD + P.O. BOX 37 + SHARON CENTER, OH 44274
P + 330.590.8004 TGCENGINEERING.COM F + 888.820.8423 TCRANE@TGCENGINEERING.COM

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NGIN FERING exemption if a safe distance is maintained from persons in accordance with 14 CFR 91.119. 6. At least 5 hours of flight experience and 3 takeoffs and landings in make and model being flown in the prior 90 days. Such cycles and hours maybe gained during flights under this exemption if a safe distance is maintained from persons in accordance with 14 CFR 91.119.
ii. A Visual Observer (VO) iii. A Sensor Operator (SO) as necessary d. AII flight operations will be conducted in accordance with valid Certificates of Authorization (COA's) e. AII flight operations will comply with the following:

i. The manufacturers' user manuals. ii. TGC Engineering, LLC Flight Operations and Procedures Manual (FOPM) and Aircraft Flight Manuals (AFM) , which include lost communication and other emergency and safety procedures. iii. Conducted in Visual Flight Requirements (VFR) conditions in Daylight Hours. iv. PIC and VO will maintain Visual Line of Sight (VLOS) at all times. v. Pre-flight inspections (including ground control station, if any) and safety risk assessments will be conducted prior to each flight. vi. Flight altitudes will remain below 400 feet above ground level (AGL). vii. Airspeeds at ground level will not exceed 50 knots. viii. Not to encroach into limits of Class B, C or D Airspace, or published approach, Standard Instrument Departures Areas (SID) or Standard Terminal Arrival Areas (STAR), or take place within 5 nautical miles of an airport. ix. Not be made near persons as required by 14 CFR 91.119 and not over persons on the ground without their prior permission. 

### x. Each flight will be logged in both the PIC's logbook and the aircraft logbook. xi. Not exceed 75% of the battery or fuel capacity of the aircraft, or 30 minutes, whichever occurs first. xii. Any incidents will be reported with 24 hours of occurrence. xiii. Any applicable local Flight Standards District Office (FSDO) requirements. xiv. AII other applicable regulations concerned with the operation of aircraft.
f. Aircraft will utilize FCC compliant 2.4 GHz for command & control of the aircraft with welldefined and test lost link procedures. 

### Please advise of any additional information or revisions that may be required Sincerely,

Jeremy M. Sack, P.S. Project Manager, TGC Engineering, LLC

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### TGC ENGINEERING + 1310 SHARON COPLEY RD + P.O. BOX 37 + SHARON CENTER, OH 44274

P + 330.590.8004 TGCENGINEERING.COM F + 888.820.8423 TCRANE@TGCENGINEERING.COM