September 21, 2015

Exemption No. 12931

Regulatory Docket No. FAA−2015−2480

Mr. Jeremy Abshire

Unmanned Tropo Reconnaissance 

12011 Indian Wells Drive

Houston, TX 77066

Dear Mr. Abshire:

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 June 1, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Unmanned Tropo Reconnaissance (hereinafter petitioner or operator) for an 

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

conduct aerial video, photogrammetry, light detection and ranging, thermal imagery, 

inspections, construction, surveys, aerial mapping, and quantitative volume and estimating 

analysis.

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.

Airworthiness Certification

The UAS proposed by the petitioner is a Tarot T18.

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 
2

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 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, Unmanned Tropo Reconnaissance 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 

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

below.

 

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.
3

Conditions and Limitations

In this grant of exemption, Unmanned Tropo Reconnaissance 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 Tarot T18 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 

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, 
4

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 

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.
5

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 

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.
6

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 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.
7

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.
8

This exemption terminates on September 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Page 1 of 11

Unmanned Tropo 

Reconnaissance

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

UNMANNED TROPO RECONNAISSANCE (U.T.R.)

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

§ 61.113 (a) & (b), § 91.7(a), § 91.121, § 91.151(b), § 91.405(a), § 91.407(a)(1), § 91.409(a)(1) 

& (a)(2), AND § 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF A TAROT 

T18 UNMANNED AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF THE FAA 

MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95).

Submitted on June 1, 2015

Contact Information

Unmanned Tropo Reconnaissance (U.T.R.),

Jeremy Abshire

12011 Indian Wells Dr.

Houston, Texas 77066

Phone: (832) 799-1106

Email: utrsua@gmail.com
Page 2 of 11

Contents

Contact Information.................................................................................................................................1

Glossary of Abbreviations.....................................................................................................................2

Summery ....................................................................................................................................................3

The Sections (§) of 14 C.F.R. which U.T.R. seeks Exemption......................................................3

Reasons U.T.R. seeks exemption as a relief of the above mentioned Sections of 14 C.F.R.

......................................................................................................................................................................6

UAS............................................................................................................................................................11

Conclusion...............................................................................................................................................11

Glossary of Abbreviations

AD Airworthiness Directives

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Mod and Reform Act of 2012 (FMRA) Section 333

SOP Standard Operating Procedures

UAV Unmanned Aircraft Vehicle

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Takeoff and Landing
Page 3 of 11

Summery

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and Title 14 Code of 

Federal Regulations Part 11. Unmanned Tropo Reconnaissance (U.T.R.), seeks an exemption 

from Federal Aviation Regulations Sections to allow the operation of an Unmanned Aircraft 

System (UAS) for the commercial purpose of conducting aerial video, photogrammetry, LIDAR, 

thermal imagery, inspections, construction, preliminary thru asbuilt surveys, aerial mapping and 

quantitative volume and estimating analysis, in, across, through and or beyond the NAS in an

attentive and safe manner.

The Sections (§) of 14 C.F.R. which U.T.R. seeks Exemption.

§ 61.113 (a) & § 61.113 (b), entitled Private pilot privileges and limitations: Pilot 

in command, subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in 

command (PIC) of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, act as PIC of 

an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if:

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for 

compensation or hire.

§ 91.7 (a), entitled Civil aircraft airworthiness, subsection (a), states the following: (a) 

No person may operate a civil aircraft unless it is in an airworthy condition.

§ 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level 

of that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating

(1) Below 18,000 feet MSL, to-

(i) The current reported altimeter setting of a station along the route 

and within 100 nautical miles of the aircraft;
Page 4 of 11

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of 

this section, the current reported altimeter setting of an appropriate 

available station; or

In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before 

departure.

§ 91.151 (b), entitled Fuel requirements for flight in VFR conditions, subsection (b), 

states the following:

(b) No person may begin a flight in a rotorcraft 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, to fly after that for 

at least 20 minutes.

§ 91.405 (a), entitled Maintenance required, subsection (a), states the following:

Each owner or operator of an aircraft—

(a) 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[.]

§ 91.407 (a) (1), entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a) (1), and states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless-

(1) It has been approved for return to service by a person authorized under § 

43.7 of this chapter [.]

§ 91.409 (a) (1) & § 91.409 (a) (2), entitled Inspections, subsection (a), states the 

following:

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had -

(2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter.
Page 5 of 11

§ 91.417 (a) & § 91.417 (b), entitled Maintenance records, subsections (a) and (b), state 

the following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods 

specified in paragraph

(b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and each engine, 

propeller, rotor, and appliance of an aircraft. The records must include--

(i) A description (or reference to data acceptable to the Administrator) 

of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving 

the aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each 

propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, 

engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft 

which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time 

since the last inspection required by the inspection program under which the 

aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and 

safety directives including, for each, the method of compliance, the AD or 

safety directive number and revision date. If the AD or safety directive involves 

recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for 

each major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances.
Page 6 of 11

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after the work is 

performed.

(2) The records specified in paragraph (a) (2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 

of this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service.

Reasons U.T.R. seeks exemption as a relief of the above mentioned 

Sections of 14 C.F.R. 

§ 61.113 (a) & § 61.113 (b), entitled Private pilot privileges and limitations: Pilot 

in command, subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in 

command (PIC) of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, act as PIC of 

an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if:

(3) The flight is only incidental to that business or employment; and

(4) The aircraft does not carry passengers or property for compensation or hire.

Reason 

First, unlike a conventional manned aircraft, the aircraft is remotely controlled 

by a ground-based pilot operator in a controlled and restricted area. Second, the aircraft is 

much smaller than a manned aircraft that the level of risk associated with its' operation is 

diminished from the level of risk associated with commercial operations contemplated by part 

61. Therefore, allowing aircraft use by a private pilot as the PIC meets or exceeds the 

present level of safety sought by 14 C.F.R. §61.113 (a) and (b).
Page 7 of 11

§ 91.7 (a), entitled Civil aircraft airworthiness, subsection (a), states the following: (a) 

No person may operate a civil aircraft unless it is in an airworthy condition.

Reason 

Maintaining an equivalent level of safety, the PIC will ensure that the aircraft is in 

compliance with the Pre Flight Operating Manual prior to each flight and Post Flight Operation 

Manual after each flight. Additionally, the Pilot will still comply with 91.7(b) and ensure that the 

aircraft is in condition for a safe flight.

§ 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level 

of that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating

(1) Below 18,000 feet MSL, to

(i) The current reported altimeter setting of a station along the route 

and within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of 

this section, the current reported altimeter setting of an appropriate 

available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before 

departure.

Reason 

The T18 does not have a barometric altimeter, but instead uses GPS altitude data. 

U.T.R. establishes an equivalent level of safety by requiring the Pilot to confirm that the GPS 

altitude is set to zero at ground level before every flight.
Page 8 of 11

§ 91.151 (b), entitled Fuel requirements for flight in VFR conditions, subsection (b), 

states the following:

(b) No person may begin a flight in a rotorcraft 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, to fly after that for 

at least 20 minutes.

Reason 

The battery powering the T18 provides approximately 25 minutes of powered flight 

and therefore is unable to meet this requirement. However, flights will not go beyond % mile 

of the intended landing point and will remain in line of sight at all times. The T18 has a low 

battery function that automatically sends the aircraft back to its departure point and a critical 

battery function which automatically lands the aircraft. Also, because the aircraft will be flying 

in a confined area without the presence of non-essential persons and with landowner and or 

controller permission, an equivalent level of safety can be achieved by flight planning all 

flights to return to intended landing site with approximately 15% reserve power.

Due to the similarities in nature (maintenance) the remainder of the Sections will be 

reasoned with as one

§ 91.405 (a), entitled Maintenance required, subsection (a), states the following:

Each owner or operator of an aircraft

(b) 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[.]

§ 91.407 (a) (1), entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a) (1), and states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless-

(1) It has been approved for return to service by a person authorized under § 

43.7 of this chapter [.]
Page 9 of 11

§ 91.409 (a) (1) & § 91.409 (a) (2), entitled Inspections, subsection (a), states the 

following:

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had -

(2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter.

§ 91.417 (a) & § 91.417 (b), entitled Maintenance records, subsections (a) and (b), state 

the following:

(c) Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods 

specified in paragraph

(d) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and each engine, 

propeller, rotor, and appliance of an aircraft. The records must include--

(i) A description (or reference to data acceptable to the Administrator) 

of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving 

the aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each 

propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, 

engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft 

which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time 

since the last inspection required by the inspection program under which the 

aircraft and its appliances are maintained.
Page 10 of 11

(v) The current status of applicable airworthiness directives (AD) and 

safety directives including, for each, the method of compliance, the AD or 

safety directive number and revision date. If the AD or safety directive involves 

recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for 

each major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after the work is 

performed.

(2) The records specified in paragraph (a) (2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 

of this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service.

Reason

These sections and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to U.T.R.’s operations. Maintenance will be accomplished by U.T.R. in 

accordance with U.T.R.’s Operations Manual. The PIC will ensure that the aircraft is in working 

order before and after flight mission. The PIC will perform needed inspection and minor 

maintenance of the aircraft. Additionally, the PIC will conduct detailed inspections of the aircraft 

every 10 hours of flight intervals. Maintenance performed by the PIC is limited to field repairs. 

All other maintenance, updates, upgrades and repairs will be completed by a qualified 

technician before and after mobilization to project location.

U.T.R. will keep a log of maintenance performed. Moreover, U.T.R. and the PIC are 

most familiar with the aircraft and best suited to maintain it in an airworthy condition. An 

equivalent level of safety will be achieved because the T18 is limited in size, will carry a small 

payload and operate only in restricted areas for limited periods of time. The T18 is designed 

to maintain flight with the failure of one motor. If mechanical issues arise, the aircraft can land 

immediately and will be operating from no higher than 400 feet AGL.
Page 11 of 11

UAS

The Tarot T18 is an Octocopter frame (size and material almost identical to the 

S1000.) U.T.R.’s T18 is equipped with the DJI A2 flight control system, the same as S1000 

as well as the Inspire.

http://www.dji.com/product/a2

Tarot T18 specifications:

- Wing span: 3’ 7”

- Height: 16.5”

- Net weight: 24.25 lbs.

- Speed: 50 mph

http://www.tarot-rc.com/index.php?main_page=product_info&cPath=65_98&products_id=1150

Transmitter: Futaba T14SG

http://www.futaba-rc.com/systems/futk9410-14sg/

Conclusion

U.T.R. will provide clients with expertise and knowledge in advanced technologies and solutions 

to increase safety, efficiency, productivity and effectiveness. U.T.R. has over three combined 

years of operating various radio controlled technologies, has over 10 years of professional 

experience in many aspects of aerial imagery, GIS, land surveying, mapping and mapping data 

collection. In addition, he has an in depth understanding of GPS technology in which aids in the 

control and tracking system of the listed UAS. The objective of U.T.R. is to provide high quality 

imaging and data for a variety of commercial and residential uses in a safe manner, targeting:

 Real estate 

 Construction preliminary thru asbuilt surveys

 Cost estimates and quantities

 Data collection

 Aerial data and imagery for inspections of structures and facilities.

Building Inspection operations

U.T.R. will utilize this exemption to increase the safety of today’s data acquisition practices 

along with today’s inspection practices and decrease traffic of manned aircraft in the intended 

industries.