February 12,2016

U.S. Department of

### Transportation Docket Management System 1200 New |ersey Ave., SE Washington, DC20590

Request

### for Exemption under Section 333 ofthe FAA Modernization and Reform Actof 2072 and Part 11

### of the Federal 

### Aviation Regulations.

Dear Sir or Madam:

Pursuant to section 333 ofthe FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 CFR Part 11, I, Stephen T. Tardanico, dba TSTAerials, hereby apply for an exemption 

### from Federal 

### Aviation Regulations to allow commercial operations of small unmanned aerial systems (sUASJ for the purpose

### of acquiring aerial images, photography, videography, advertisement, aerial inspections, construction site development and documentation, crop management private and municipal demonstration and

### training, real estate marketing, and private events.

Name and Address of Petitioner: Stephen T.Tardanico dba TST Aerials 9 OId Main Street Carver, MA 02330 508-866-6966 (home) 508-326-8037 

### fcell) tsttruck@comcast 

### net

The specific sections of 14 CFRfrom which I seek exemption are:

14 CFR 

### Part2l subpart H 14 CFR4s.23(b) 14 CFR45.29 14 CFR 61.113[a) and 

### [b) 14 CFR 91.7 (a) 14 cFR e1.e 

### (b) (21 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119[c) 14 CFR

### 9t.121 14 CFR91.151(a) 14 CFR 91".203 [a) and 

### [b) 14 CFR91.405(a) 14 CFR e1..a07@) (1) 14 CFR 91.40q (a) 

### [1) and 

### [2) 14 CFR 91".417[a) and (b)The extent of relief and reasons I seek relief are:



### 14 CFR 

## Part?l-, Subpart 

## H:

## Airworthiness Certificates, 14 CFR 

## 91.203 (a) 

## (1) Subpart H,

### Airworthiness Certificates, establishes the procedural requirements for the issuance 

### of airworthiness certificates as required by CFR 91.203 (a)

## tf). Given the small size and 

### limited operating area associated 

### with the sUAS to be utilized by me, an exemption 

### from Part 21 Subpart H meets the requirements 

### ofan equivalent level 

### ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.S44701 

### (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt

### aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size,weighg speed, operational capability, and 

### proximity to 

### airports and populated areas ofthe 

### particular sUAS.

The sUAS to be operated is less than 55 pounds

### fully loaded, carries neither a

### pilot nor passengers, carries no explosive materials orflammable 

### liquid fuels, and operates exclusively

### within apredefined area.Operating the sUAS 

### without an airworthiness certificate, inthe 

### restricted environment and under the conditions proposed inthis 

### petition

### will be at least as safe, or safer, than aconventional 

### aircraft ffixed wing 

### or rotorcraft) operating 

### with an 

### airworthiness certificate 

### without the restrictions and conditions proposed.


### 14 CFR

### 45.23 

## (b) and 14 CFR

## 45.29: Marking of

## the

## Aircraft Section 45.23 (b) states

### that "When marks include 

### onlythe Roman capital 

### letter "N" and the 

### registration number isdisplayed on 

### limited, restricted or 

### light-sport category 

### aircraft or experimental or 

### provisionally certificated 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 "provisional," as applicable". The sUAS has no entrance to acabin, cockpit or 

### pilot station onwhich the 

### word "Experimental" can be placed. Giventhe size ofthe sUAS,

### two-inch lettering is impractical. I seek an exemption 

### from CFR 45.23. I

### will ensure compliance 

### with 45.29(fl to meet the 

### intent ofthe regulation by displaying the unique FAA 

### registration number in the largest practicable 

### lettering.


### 14 CFR

## 6L.L13 (a) & 

## (b): Private Pilot Privileges and 

## Limitations; Pilot in Command Sections 61.113 [a) & 

### [b) limits private pilots to non-commercial operations. Unlike aconventional 

### aircraft that carriesthe 

### pilot and passengers, the sUAS is remotely controlled and carries no passengers.The area 

### of operation iscontrolled. An equivalent level 

### ofsafety can be achieved by 

### requiringthe PIC operating 

### the aircraftto have a private 

### pilot's license. The risks associated 

### with the operation ofthe sUAS are sodiminished from the level of risk associated 

### with commercial operations of conventional 

### aircraft carrying combustible fuel and passengers, that allowing operations of the sUAS as requested 

### with a private 

### pilot asthe PIC exceeds the present level of safety achieved by 14 C.F.R. 61.113 (a) & (b).

Iam a private 

### pilot and my certificate number isavailable upon request. Since there are 

### currently no applicable areas 

### identified for sUAS in either the private or t}recommercial sector, I seek an exemption 

### to conduct commercial operations.


### 14 CFR 

## 91.7(a)t Civil

## Aircraft Airworthiness The regulation requires that no person may operate acivil 

### aircraft unless 

### it is in

### airworthy condition. As

### there 

### will be no airworthiness certificate issued for the aircraft, shouldthis exemption be granted, no FAA regulatory standard

### will exist for determining airworthiness. An equivalent level of safety 

### will be provided by my inspection ofthe sUAS 

### prior to each 

### flight and by complying 

### with maintenance procedures outlined by

### the manufacturer.



### 14 CFR

## 91.9 

## [b] 

# (2]: Civil

## Aircraft Flight Manual 

## inthe

## Aircraft Section 91.9 (bJ (2) provides that no person may operate a U.S. registered 

### civil aircraft- [2) Forwhich anAirplane or Rotorcraft Flight Manual is not required by 921.5 ofthis chapter, unless there is available inthe 

### aircraft acurrent approved airplane 

### or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.The sUAS, given its size and configuration has no 

### ability or placeto carry such a

### flight manual on the 

### aircraft.

The equivalent level of safety

### will be maintained by keeping the 

### flight manual at aground control 

### pointwhere I

### will have immediate accessto it. The FAA has issued the

### following exemptions to this 

### regulation: Exemption Nos. 8607, 

### 8737,8738,9299,9299A,9565, 95658,1.0167,7A767A,1A6A2,32827, and 10700.


### 14 CFR

## 91.103: Preflight Action Section 91.103 requires each 

### pilotto 

### preflight an 

### aircraft before 

### flight to insure the safety offlight. As FAA approved 

### rotorcraft flight manuals 

### will not be used, an exemption is requested. However, an equivalent level of safety

### will be provided by making all 

### preflight inspections of my sUAS as outlined in the owner's manual, including reviewing weather, 

### flight battery requirements, predetermined operating area, and 

### aircraft maintenance data before commencement of

### flight.


### 14 CFR

## 91.109: Ftight 

## Insffuction Section 91.109 (a) statesthat no person may operate a

### civil aircraft (except a manned free balloon) that is being usedfor 

### flight instruction unless that 

### aircraft has 

### fully functioning dual controls. sUASs and remotely piloted aircraft, by

### their design do not have

### fully functional dual controls. Therefore the exemption is requested to

### train operators, 

### build experience, and maintain proficiency. The FAA has approved exemptions for 

### flighttraining without fully functional dual controls for a number of

### aircraft and

### for

### flight instruction in experimental 

### aircraft The equivalent level of safety is provided by the fact that neither a

### pilot
nor passengers

### will be carried inthe sUAS and by the size and speed ofthe 

### aircraft.


### 14 CFR 

### 91.1L92 

## Minimum SafeAltitudes Section 91.119 establishes safe altitudes for operation of

### civil aircraft. Section 91.L19 

### [d) allows helicopters to be operated at less thanthe minimums prescribed, provided the person operating the helicopter complies 

### with any route or altitudes prescribed for helicopters by the FAA.Asthis exemption isfor a sUAS that is a helicopter and the exemption requests 

### authority to operate at altitudes upto 400 AGL, an exemption may be neededto allow suchoperations. As set

### forth herein, the sUAS 

### will never operate at higher than 400 AGL. 

### It will however be operated in a safe and predetermined area. The equivalent level of safety 

### will be achieved given the size, weight, and speed ofthe sUAS as

### well asthe location where 

### it is operated. No 

### flight

### will be taken

### without the permission of the 

### property owner or local officials. Because ofthe advance notice to the 

### property owner, all affected individuals 

### will be aware of the planned

### flight operations. Compared to

### flight operations 

### with aircraft or 

### rotorcraft weighing far more than the maximum 55lbs. proposed herein andthe lack offlammable fuel, any 

### risk associated 

### with these operations isfar less than those presently presented 

### with conventional 

### aircraft operating ator below 500 AGL. In addition, the 

### low-altitude operations ofthe sUAS 

### will ensure separation between these sUAS operations andthe operations of conventional 

### aircraftthat must comply

### with Section 97.719.


### 14 CFR 

## 9L.12Lr 

## Altimeter Settings This regulation requires each person operating an

### aircraftto maintain cruising 

### altitude by reference to an altimeter that is set "...to the elevation ofthe departure 

### airport or an appropriate 

### altimeter setting available before departure." Asthe sUAS may not have abarometric altimeter, but instead a GPS

### altitude read out, an exemption may be needed.An equivalent level of safety

### will be achieved by meconfirming the 

### altitude of

### the Iaunch site shown on the GPS

### altitude indicator before

### flight


### 14 CFR

## 91.151(a): Fuel 

## Requirements 

## for Flight in VFR 

## Conditions Section 91.151 (a) 

### 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 Ianding, 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 battery powering the sUAS 

### typically provides less than 30 minutes of powered flight. To meet the 30 minute reserve requirement 

### in 14 CFR 

### 91.151would not be possible. I

### will ensure that an equivalent level of safety 

### will be achieved by 

### limiting flights to 25o/o of remaining 

### battery power andthat flights are completed

### with battery power remaining. This 

### restriction 

### will be morethan adequate to 

### return the sUAS to the proposed landing zone

### from anywhere in its 

### limited operating area anddoes not promote the type of risks

### that Section 91.151(a) was intended to alleviate. Similar exemptions have

been granted to other operations, including Exemptions 2689F

, 57 45, 10673, and 10808.


### 14 CFR 

## 91.203 (a) and 

## (b): Carrying Civil

## Aircraft Certification and 

## Registration The regulation provides in 

### perlinent part: (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. [bJ No person may operate acivil 

### aircraft unless the airworthiness cerrificate required by paragraph [a) 

### of this section or aspecial 

### flight authorization issued under 

### 91.7t5 isdisplayed atthe cabin or cockpit entrance

sothat 

### it is legible to passengers or crew. The sUAS 

### fully loaded weighs no morethan 55 lbs and is operated

### without an onboard pilot. As such, there is
no

### ability or placeto carry 

### certification and 

### registration documents or to display them on the sUAS. An equivalent level of safety 

### will be achieved by keeping all operating documents atthe ground 

### control 

### point where I

### will have immediate accessto them. The FAA has issued numerous exemptionsto this regulation.


### 14 CFR

## 91.405 

## (a);4O7 (a) (1); a09 

## [a) (Z);

# afi@) & 

## [b): Maintenance Inspections These regulations require 

### that an

### aircraft operator or owner "shall havethat 

### aircraft inspected as prescribed in Subpart E

### ofthis part and shall between required inspections, except as provided in paragraph [cJ

### ofthis section, have discrepancies repaired as prescribed in Part 43 

### ofthis chapter...," and others shall inspect

### or maintain the 

### aircraft in compliance 

### with Part 43. Given that these sections and Part 43 apply only to 

### aircraft

### with an airworthiness certificate, these sections 

### will not apply to the 

### applicant Maintenance 

### will be accomplished by me 

### in accordance 

### with manufacturer's guidelines. An equivalent level of safety 

### will be achieved because the sUAS isvery 

### limited in size and

### will carry asmall payload and operate only in predetermined areas 

### for limited periods oftime. If mechanical issues arise the sUAS can land immediately and

### will be operating 

### from no higher than 400 feetAGL. I

### will
ensure that the sUAS is in

### working order 

### prior to 

### initiating 

### flight perform required maintenance, and keep a Iog ofall maintenance performed. Moreover, I amthe person most

### familiar with the 

### aircraft and best suited

### to maintain the 

### aircraft in an

### airworthy condition to provide the equivalent level of safety.


## How my request 

## would benefit the 

## public as a

## whole: My request 

### for the commercial use of a sUAV

### would benefit the public as awhole 

### in numerous ways. The greatest benefit would be 

### little to no carbon 

### footprint left behind by the use of a sUAS, as compared to the enormous amounts of fuel, 

### oil and emissions that are associated 

### with full scale aircraft. Another public benefit 

### would bethe 

### elimination of noise pollution, which can be annoying, and depending on 

### proximity and decibels,
can be e)cremely frightening aswell. The public 

### would also benefit bythe lack of damage caused by

### flying dust and debris induced by 

### rotor or prop wash and turbulence associated 

### with low 

### flyingfull scale 

### aircraft. The economic benefit to the public includes acost effective answer for an otherwise expensive service, allowing more money to be spent throughout the economy. The ever evolving use ofthe sUAS 

### will continue

### to provide public benefit asthe 

### technolory and applications continue to aspire to new heights. 

## Why my 

## exemptionwould not adversely affect safety, and 

## how 

## itwould provide a 

## level of

## safety at 

## least equal tothe existing 

## rulei My commercial operation of a sUAS 

### will enhance safety by reducing risk. The size, weight, speed, and 

### limited operating areas of t}re sUASsignificantly improves safety and reduces the 

### risk of 

### injury or 

### property damage and

### will be at least as safe, or safer than

### full scale 

### aircraft carrying crew and fuel.AIsothe use of a sUAS

### will reduce the 

### risk of slip and

### fall injuries during inspections involving height. The sUAS has afailsafe system

### that insures any loss of signal of interference 

### will return the sUAS to the predetermined landing 

### point. Another level of safety can be achieved by demonstrating, training, and 

### informing the general public of 

### know "B4UFLY". To ensure safety I

### will comply 

### with all applicable parts of 14 CFR as outlined in conditions and 

### limitations by the FAA,and adhere to the operations manual ofthe specific sUAS.

## Summary;

My sUAS operation 

### will be safely conducted to minimize risk by 

### utilizing GPS

### technolory and programming parameters ofthe specific area of operation. In the event of an emergenry, the sUAS

### will autonomously land safely at a predetermined location via the failsafe mode. AII 

### preflight inspections, maintenance, and repairs

### will be conducted safely as per instructions as stated in

### the user manual. 

### All test flights conducted after any maintenance or repairs

### will be in a safe area no less than 500 feet

### from persons, structures, and personal 

### property. The radio frequency used

### will be 2.4 GHz,which has been proven to be extremely reliable. AIso 5.8 GHz

### will be usedto 

### transmit live video feed as

### well as GPStelemetry and

### flight data pertaining to the safe operation 

### of the sUAS. Iam a private 

### pilot holding a 3rd class medical and a DOT/CDL medical 

### with no restrictions. Iam a member of the Academy of Model Aeronautics. Iam a UScitizen, and aveteran ofthe USArmy. I pose no threat to the security and safety ofthe NAS. I have over 25 years of experience 

### building repairing, programming, and

### flying RCairplanes, helicopters and recently 

### multirotor aircraft. This level of experience more than qualifies me to maintain the level of safety required for the safe operation of my sUAS. Myvisual observer 

### will be

### trained by me, and

### will be 

### proficient with all procedures necessary to conduct safe operation of my sUAS inthe event of an emergency, or any other unforeseen issue. AII flights conducted for the specific services listed 

### will be in apredetermined area clear of non 

### participating persons and 

### property

### within the visual line ofsight of me and my VO.

### All flights 

### will be no higher than 400 feet AGL,at airspeeds not to exceed 87 knots or as recommended by the manufacturer, in VMC conditions, no Iessthan 3 statute miles 

### visibility, no less than 500 feet below and no less than 2000 feet 

### horizontal from clouds. I

### will give way and maintain adequate separation from manned 

### aircraft operations and activities, which 

### will exhibit a level of safety at least equivalent to that provided bythe rule from which exemption is sought. Any accident or incident that results 

### in injury or 

### property damage

### will be reported to the FAA's UAS 

### Integration Office

### within 24 hours. Accidents 

### will be reported to the NTSB as per instructions. Inthe event aspecific service is required 

### within a 5 nautical mile radius of a local 

### airport, a

### letter 

### of agreement 

### will be obtained from the 

### airport's managemen! and made available upon request. The make and model of the 

### aircraft for proposed operations are asfollows: DfI Phantom L, DfI Phantom 3 Pro, Df

### l Inspire 1 Pro, Df

### l Spreading Wings 51000, and Yuneec Q500. 

### All manuals and operating instructions for these

### aircraft are readily available on line.

Thank youfor 

### your consideration.
Respectfu 

### lly submitted,

dba TSTAerials 9 Old Main Street Carver, MA 02330 tsftruck@comqaSt.net 

# n*ffulf{m "/" steph& 

### r. rarrianico