cot) 

US Department of Transportation 

Federal Aviation Administration 

800 Independence Ave, SW 

Washington, DC 20591 

c 

September 8, 2015 O 

io 

C 

Re: Request for Certificate of Waiver or Authority from FAA Modernization and Reform ~ 

Act of 2012, Public Law 1112-95 FEB 14, 2012, Section 333 

P 

To whom it may concern: 

T 

Concepts To Operations, Inc. (CTO) is an engineering and consulting firm focused on 

public safety communications. Over its twenty-five year history, CTO has provided S 

needs assessments of infrastructure, radio system design procurement assistance, 

and project management for system implementation. Many of our projects have 

involved assessments of tower infrastructure and a determination of suitability for 

additional FCC licensed antennas and equipment. In its history, CTO has served as T 

frequency coordinator for the Naval Electromagnetic Spectrum Center 

(NAVEMSCEN), design and implementation consultant for FDNY Channel 16 and O 

DoITT Channel 16 (post-9/11), as well as the design team for the new 800 MHz radio 

system utilized by the US Capitol Police. 

Our contact information is as follows: O 

Concepts To Operations, Inc. P 

800 Compass Way, Suite 217 

Annapolis, MD 21401 

E (410) 224-8911 

ctoCa)-concept2ops.com n 

We are seeking exemption from FAA Modernization and Reform Act of 2012, Public ~ 

Law 1112-95 FEB 14, 2012, Section 333. With the advent of technology, and the use 

of UAVs for assessment and evaluation, our clients have begun to ask if CTO can ~ 

provide that service as part of our projects. 

Our exemption from this rule would benefit the public as a whole because public 1 

safety entities are in the process of upgrading to the P25 standard, which requires O 

new antennas and equipment on existing infrastructure. Most of the infrastructure is 

comprised of older towers that lack accurate records of antenna type, height, and 

cabling connections. These elements are critical for determining structural integrity N 

under the new rules that have been issued by the National Public Safety 

Telecommunications Council (NPSTC) for public safety grade facilities. S 

Concepts To Operations, Inc. 

Corporate Offices: 801 Compass Way, Suite 217, Annapolis, MD 21401-7813 —(410) 224-8911 — cto@concepts2ops.com 
CTO believes that approval of our exemption will benefit the public by providing a safe 

and cost effective option for obtaining the critical information needed without having to 

initiate a tower climb. This alternative will save significant taxpayer dollars (public safety 

budgets). 

Granting our exemption would not adversely affect safety because, as CTO notes, the 

planned operations would be in the immediate area of the tower, and that towers 

intruding on FAA airspace would already have a preexisting FAA clearance (circle 

study). CTO foresees no reason that the UAS would need to operate outside of direct 

line of sight of the pilot and observer. 

The normal operations consist of the following: 

• 30 days prior to scheduled flight, certified letter will be sent to the registered 

tower owner (FCC ASR), and any airport or secured facility, of date/time of 

inspection flight 

o Letter shall include purpose of inspection flight, names of flight team, 

location of any airport within a 5 mile radius, contact information, and flight 

records location 

• On the date of flight, flight team will: 

• Verify all local regulations 

• Pre-define flight pattern and location 

• Define size of imagery 

• Define flight height 

• Define number of images to be captured 

• Verify weather 

• Upon arrival at tower site, flight team will: 

• Walk entire area of flight path to identify obstructions or hazards 

• Clear the area of people and animals using bullhorn 

• Visually check UAS batteries 

• Visually inspect UAS for any sign of damage due to transport 

• Inspect propeller gimbal camera and remote 

• Verify SD card is available for current images required 

• Turn on all devices and connect WiFi for in-flight video 

• Prior to flight: 

• Will calibrate compass 

• Test for full 3600range of motion 

• Set UAS on flat surface with at least 15' open radius to compensate for 

"return to home" GPS accuracy with the camera facing away from the 

operator 

• Verify communications with the UAS snd that the UAS has acquired GPS 

location from at least 6 satellites; the UAS will record the "Home" position 

and the LED indicators will flash to let the operator know "Home" has been 

set 

Concepts To Operations, Inc. 

Corporate Offices: 801 Compass Way, Suite 217, Annapolis, MD 21401-7813 —(410) 224-8911 — cto@concepts2ops.com 
• Initiate flight 

• Slowly lift the UAS to 10' to assess UAS stability 

• Verify all controller operations for heading and altitude 

• Initiate communications between operator and observer 

• Land UAS and prepare for autonomous flight, if autonomous mode is 

being used 

• Commence flight plan or initiate autonomous flight, if autonomous mode is 

being used 

■ Operator and observer shall maintain visual line of sight of UAS at 

all times to ensure safe operation and flight termination for any 

safety reasons 

• Completion of flight plan 

o UAS to be landed in a 10' free zone and allowed to remain undisturbed for 

a 5 minute period after propeller shutdown 

• Observer shall remove the SD from the UAS camera and download images 

• Operator shall inspect the UAS after each flight and shall properly store UAS in a 

protected storage crate 

The following is a summary that may be published in the Federal Register: 

Concepts To Operations, Inc. (CTO) is seeking exemption from FAA 

Modernization and Reform Act of 2012, Public Law 1112-95 FEB 14, 2012, 

Section 333 in order to provide UAS services to public safety clientele who have 

requested this service and who are in the process of large-scale radio system 

upgrades involving tower infrastructure. Concepts To Operations is an 

engineering and consulting firm focused on public safety communications. Many 

of our projects have involved assessments of tower infrastructure and a 

determination of suitability for additional FCC licensed antennas and equipment. 

CTO believes that approval of our exemption will benefit the public by providing a 

safe and cost effective option for obtaining the critical information needed without 

having to initiate a tower climb. 

Lastly, we have no need to exercise the privileges of this exemption outside of the 

United States at this time. 

Respectfully, 

Charle~ ~~ I I I, Esq. 

Vice qres en of Operations 

Concepts To Operations, Inc. 

Corporate Offices: 801 Compass Way, Suite 217, Annapolis, MD 21401-7813 —(410) 224-8911 — cto@concepts2ops.com