July 21, 2015

Exemption No. 12099

Regulatory Docket No. FAA–2015–0991

Mr. Curt Daniels

Vice President

Seminole Club, Inc., DBA: Tower Specs

707 West Park Avenue

Suite D

Edgewater, FL 32132

Dear Mr. Daniels:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated April 6, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Seminole Club, Inc., DBA: Tower Specs (hereinafter petitioner or operator) for an 

exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct cell phone and antenna tower inspections.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner. However, the FAA 

received one individual comment in support of the petition made to the docket.

Airworthiness Certification

The UAS proposed by the petitioner is a CarbonCore Octocopter 1000.
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The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Seminole Club, Inc., DBA: Tower Specs is granted an 

exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 

91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform 

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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aerial data collection. This exemption is subject to the conditions and limitations listed 

below.

Conditions and Limitations

In this grant of exemption, Seminole Club, Inc., DBA: Tower Specs is hereafter referred to as 

the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the CarbonCore 

Octocopter 1000 when weighing less than 55 pounds including payload. Proposed 

operations of any other aircraft will require a new petition or a petition to amend this 

exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 
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exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

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

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 
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government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 
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exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

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

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must 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 UA and/or debris in the event of an accident. The operator must 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 UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 
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reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on July 31, 2017, unless sooner superseded or rescinded.

Sincerely,

John S. Duncan

Director, Flight Standards Service

Enclosures
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Seminole Club, Inc.

DBA: Tower Specs

April 6, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation

Regulations from 14 C.F.R. 45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91 .9 (b)

(2); 91.103(b); 91 .109; 91.119; 91 .121; 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407(a) (1);

91.409 (a) (2); 91.417 (a) & (b).

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, Seminole Club, Inc., DBA: Tower Specs, hereby applies for an 

exemption from the listed Federal Aviation Regulations ("FAR") to allow commercial operation of 

its UAV’s, 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.

As described more fully below, the requested exemption would permit the operation of small, 

unmanned UAV’s under controlled conditions in airspace that is 1) limited 2) predetermined 3) 

Controlled as to access and 4) would provide cell phone and antenna tower inspections. We will 

be operating in airspace previously reviewed by the FAA for the construction of the tower 

therefore the airspace of the controlled operations area creates no additional hazard to the 

national airspace. Approval of this exemption would therefore create no safety concerns 

regarding national airspace and fulfill the Secretary of Transportation's (the FAA Administrator's) 

responsibilities to " ... establish requirements for the safe operation of such aircraft systems in the 

national airspace system." Section 333(c) of the Reform Act.

The name and address of the applicant is:

Seminole Club, Inc. 

DBA: Tower Specs

Attn: Curt Daniels

Email curt@towerspecs.com

707 West Park Ave

Suite D

Edgewater, Florida 32132

(386) 410-4701

Regulations from which the exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23 (b)

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109
2

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151 (a)

14 C.F.R. 91.203 (a) & (b)

14 C.F.R. 91.405 (a)

14 C.F.R. 407 (a) (1)

14 C.F.R. 409 (a) (2)

14 C.F.R. 417 (a) & (b)

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 332 of the Reform Act. In making this determination, the Secretary is required to 

determine which types of UAV 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 UAV size, weight, speed, and operational capability;

• Operation of the UAV in close proximity to airports and populated areas; and

• Operation of the UAV 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." Applicant interprets this provision 

to place the duty on the Administrator to not only process applications for exemptions under 

section 333, 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. The Federal Aviation Act expressly grants the FAA the authority 

to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as 

the term is defined under §401 01 of the Act that includes UAV, from the requirement that all 

civil aircraft must have a current 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 exemption in the public interest. 49 U.S.C. §44701(f) See also 49 

USC §44711(a); 49 USC §44704; 14 CFR §91.203(a) (1).

Tower Specs UAV’s are rotorcraft, weighing 55 or fewer lbs. including payload. They

operate, under normal conditions, at a speed of no more than 50 knots and have the 

capability to hover, and move in the vertical and horizontal plane simultaneously. They will 

operate only in line of sight and will operate only within a small controlled area described in 

the Confidential Operations Procedures, attached as Exhibit A (hereinafter "Procedures") 

Such operations will insure that the UAV will "not create a hazard to users of the national 

airspace system or the public.''

Applicant submits this Procedure as a Confidential and Proprietary document under 14

CFR 11 .35 (b) as the entire Procedures contains proprietary information that the applicant 

has not and will not share with others. The Procedures contains operating conditions and

procedures that are not available to the public and are protected from release under the 

Freedom of Information Act 5 USC 552 et.seq. Given the small size of the UAV’s involved 

and the restricted controlled 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 UAV’s to 

commence immediately. Also due to the size of the UAV’s and the controlled areas in which 
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the relevant UAV’s will operate, approval of the application presents no national security 

issue. Given the following, the grant of the requested exemptions is clearly in the public 

interest:

• Clear direction in Section 333 of the Reform Act, the authority contained in the Federal 

Aviation Act, as amended

• The level of safety surrounding the proposed operations that implements the use of HD and 

thermal imagining, and the significant public benefit

• Innovative reductions in physical dangers of personnel climbing towers (e.g., thermal 

imaging of active wasp/hornet nests, electrical “hot spots”...) and/or the use of high-rise

heavy equipment thus reduced emissions associated with allowing UAV’s operations.

Accordingly, the applicant respectfully requests that the FAA 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. These limitations

provide for an exceptional level of safety to operations. These limitations and conditions to

which Tower Specs agrees to be bound when conducting commercial operations under an 

FAA issued exemption include:

1. The UAV will weigh less than 55 lbs.

2. Flights will be operated within line of sight of operator.

3. Maximum total flight time for each operational flight will be 30 minutes. Flights will be 

terminated at 15% battery power reserve should that occur prior to the 30 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL

5. UAV operator will be trained and certified in the proper safety and operations of the UAV.

In addition, the UAV operator shall be an FAA licensed airman with at least a private pilot’s 

certificate and third class medical.

6. The UAV will only operate within a controlled area as defined in the Procedures.

7. The operator will post advisor notice around the controlled area.

8. Operator will have been trained in operation of UAV generally and received up-to-date 

information on the particular UAV to be operated as required.

9. If the UAV loses communications or loses its GPS signal, the UAS will have capability to

return to a pre-determined location within the Security Perimeter and land.

10. The UAV will have the capability to abort a flight in case of unpredicted obstacles or

emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for 

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 utilized by the

Applicant, 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 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt 

aircraft from the requirement for an airworthiness certificate, upon consideration of the size, 
4

weight, speed, operational capability, and proximity to airports and populated areas of the 

particular UAV. In all cases, 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 rotorcraft) operating with an airworthiness certificate without the restrictions and conditions 

proposed.

The UAV’s to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot 

nor passenger, carries no explosive materials or flammable liquid fuels, and operates

exclusively within a controlled area as set out in the Procedures. Unlike other civil aircraft,

operations under this exemption will be tightly controlled and monitored by the operator,

pursuant to the Procedures requirements. Lastly, application of these same criteria

demonstrates that there is no credible threat to national security posed by the UAV, due to its

size, speed of operation, location of operation, lack of explosive materials or flammable liquid

fuels, and inability to carry a substantial external load.

14 C.F.R. § 45.23(b). Marking of the Aircraft

The regulation requires:

When 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

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.

Even though the UAV will have no airworthiness certificate, an exemption may be needed as

the UAS 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 in compliance with §45.29 (f). The equivalent level of safety will be 

provided by having the UAV marked on its fuselage as required by §45.29 (f) where the 

operator working with the UAV will see the identification of the UAV as "Experimental." 

The FAA has issued the following exemptions to this regulation to Exemptions

Nos. 10700, 8738, 10167 and 10167 A

14 C.F.R. §91.7(a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy

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 and the requirements contained in the Procedures for 

maintenance and use of safety checklists prior to each flight, an equivalent level of safety will 

be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9(b)(2) provides:

No person may operate a U.S.-registered civil aircraft...
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(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 approved airplane or Rotorcraft Flight 

Manual, approved manual material, markings, and placards, or any combination thereof.

The UAV, given its size and configuration has no ability or place to carry such a flight manual 

on the aircraft, not only because there is no pilot on board, but because there is no room or 

capacity to carry such an item on the aircraft.

The equivalent level of safety will be maintained by keeping the flight manual at the ground 

control point where the operator flying the UAV will have immediate access to it. The

FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 

8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.103: Preflight action

This regulation requires each operator to take certain actions before flight to insure the safety 

of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an

exemption will be needed. An equivalent level of safety will be provided as set forth in

Procedures. The operator will take all actions including reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data before initiation of

flight.

14 C.F.R. §91.109: Flight instruction:

Section 91.103 provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual

controls.

UAV’s and remotely piloted aircraft, by their design do not have fully functional dual controls. 

Flight control is accomplished through the use of a control box that communicates with the 

aircraft via radio communications. 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. See Exemption Nos.5778K & 9862A. The equivalent level of safety

provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by 

the size and speed of the aircraft.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d)

allows helicopters to be operated at less than the minimums prescribed, provided the person

operating the helicopter complies with any route or altitudes prescribed for helicopters by the

FAA.

As this exemption is for a UAV that is a helicopter and the exemption requests authority to 

operate at altitudes up to 400 AGL, an exemption may be needed to allow such operations.

As set forth herein, except for the limited conditions stated in the Procedures, the UAV will 

never operate at higher than 400 AGL.

The equivalent level of safety will be achieved given the size, weight, and speed of the UAV 
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as well as the location where it is operated. In addition, the low-altitude operations of the 

UAV will ensure separation between these small-UAS operations and the operations of 

conventional aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by

reference to an altimeter that is set " ... to the elevation of the departure airport or an 

appropriate altimeter setting available before departure." As the UAV may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An 

equivalent level of safety will be achieved by the operator, pursuant to the Procedures and 

Safety Check list, confirming the altitude of the launch site shown on the GPS altitude 

indicator before flight.

14 C.F.R. § 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 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 battery powering the UAV provides approximately 40 minutes of powered flight. To meet 

the 30-minute reserve requirement in 14 CFR §91 .151, UAV flights would be limited to

approximately 10 minutes in length. Given the limitations on the UAV's proposed flight area

and the location of its proposed operations within a predetermined area, a longer time frame 

for flight in daylight or night VFR conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91 .151 (a) falls within the scope of prior 

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without 

compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area, with 

less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91 .151 

(a) was intended to alleviate given the size and speed of the small UAS. Additionally, limiting 

UAV flights to 10 minutes would greatly reduce the utility for which the exemption will be 

granted.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 

minutes or 15% of battery power whichever happens first. This restriction would be more

than adequate to return the UAV to its planned landing zone from anywhere in its limited

operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F,

5745, 10673, and 10808.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within 
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it the following:

(1) An appropriate and current airworthiness certificate.

(b) No person may operate a civil aircraft unless the airworthiness 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.

The UAV fully loaded weighs no more than 55 lbs and is operated without an on board 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 documents at the ground control 

point where the operator flying the UAV will have immediate access to them, to the extent they 

are applicable to the UAV. The FAA has issued numerous exemptions to this regulation. A 

representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 

9797, 9797A, 9816A, and 10700.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner "shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this 

chapter." and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the applicant. The operator will accomplish maintenance pursuant to the 

flight manual and operating handbook as referenced in the Procedures. An equivalent level of 

safety will be achieved because these small UAV’s are very limited in size and will carry a small 

payload and operate only in controlled areas for limited periods of time. If mechanical issues arise 

the UAV can land immediately and will be operating from no higher than 400 feet AGL. As 

provided in the Procedures, the operator will ensure that the UAV is in working order prior to 

initiating flight, perform required maintenance, and keep a log of any maintenance performed. 

Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the 

aircraft in an airworthy condition to provide the equivalent level of safety.

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the

Federal Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b); 14 C.F.R. §§ 61.113(a) & (b); 91.7(a); 91.9(b) (2);

91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405 (a); 91.407 (a) (1);

91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned 

vehicle (551bs or less) for the purpose of inspection, monitoring, mapping and photographing

attached equipment and engineering studies involving communication tower operations.

Approval of exemptions allowing commercial operations of UAV’s will create a level of safety by 

reducing risk. Conventional tower structure inspections and associated tasks involve extreme 

risks to personnel physically climbing such structures and/or utilizing high rise equipment both of 

which create numerous and extreme risk to such personnel. In contrast, a UAV weighing fewer 

than 55 lbs. and powered by batteries eliminates virtually all of that risk. The UAV will carry no 

passengers or crew and, therefore, will not expose personnel to any of the risks described above.

The operation of small UAV’s, weighing less than 55 lbs., conducted in the strict conditions 
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outlined above, will provide a level of safety supporting the grant of the exemptions

requested herein, including exempting the applicant from the requirements of Part 21 and

allowing commercial operations. These lightweight aircraft operate at slow speeds, close to 

the ground, and in a controlled environment.

Privacy

All flights will occur over private or controlled access property with the property owner's prior 

consent and knowledge. The granting of this exemption request will provide innovative safety 

operations.

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 and operation within 

visual line of sight and national security - provide more than adequate justification for the

grant of the requested exemptions allowing commercial operation of applicant's UAV in and

pursuant to the Procedures appended hereto.

Sincerely,

Curt Daniels

Vice President

Seminole Club, Inc

DBA: Tower Specs

Email curt@towerspecs.com

707 West Park Ave

Suite D

Edgewater, Florida 32132

(386) 410-4701