U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue S.E. 

Washington, DC 20590 

June 8, 2015 

Re: Request for Exemption under Section 333 of the FAA Modernization and 

Reform Act of 2012 and Part 11 of the Federal Aviation Regulations from 14 

C.F.R. 21(h); 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 

45.27; 14 C.F.R. 45.29; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 

91.9(c); 14 C.F.R. 91.103(b)(2); 14 C.F.R. 91.105; 14 C.F.R. 91.109; 14 C.F.R. 

91.113(b); 14 C.F.R. 91.119(b) and (c); 14 C.F.R. 91.121; 14 C.F.R. 91.151; 14 

C.F.R. 91.203(a) and (b); 14 C.F.R. 215; 14 C.F.R. 91.403; 14 C.F.R. 91.405; 

14 C.F.R. 91.407; 14 C.F.R. 409 and 14 C.F.R. 91.417 

Dear Sir or Madam: 

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform 

Act) and 14 C.F.R. Part 11, Hagen, Wilka & Archer, LLP on behalf ofNeedmore Towers, Inc. 

("NTI"), an operator of Small Unmanned Aircraft Systems ("sUAS") equipped to conduct aerial 

inspection of cellular towers, hereby applies for an exemption from the listed Federal Aviation 

Regulations ("FARs") to allow commercial operation of its sUASs, 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. The intended sUAS operations contemplated by this petition 

are in the public interest because they: replace work that is Dangerous and Difficult and at the 

same time provide an equivalent or greater level of safety than alternative manned aircraft 

operations. 

Approval of exemptions for NTI will allow commercial operations of the DJI S 1000 to 

examine cellular towers and structures in Class G airspace nationwide. The requested exemption 

should be granted because operation of small UASs, weighing approximately 24.25 lbs. (11kg.), 

inclusive of battery and payload, conducted in the strict conditions outlined below, will provide 

an equivalent level of safety, as Congress intended, while still allowing commercial operations. 

The lightweight aircraft covered by the exemption are far safer than conventional operations 

conducted with helicopters and fixed-wing aircraft weighing thousands of pounds and carrying 

highly flammable fuel, and operating in close proximity to the ground, power lines, transmission 

HAGEN, WILKA & ARCHER, LLP, Attorneys and Counselors 

Joel T. HAGEN% I Thomas K. WILKA' I John F. ARCHER I Jennifer L. RILEY"" I Jennifer L. LARSEN I Mark A. EKSE~ I Jaclyn R. S. ABERSON"' I Joseph M. WILTSE 

Also .1dmitted in: 1 Oistlic1 of Columbi.1, 0 Minn~ota, 'Iowa, TrlOfth Dakota I'.\ of counsei[ .. Registcred Patt'nt Attomcy 
otherwise involve a risk of death to the inspectors. The substantial increase of safety and decrease of risk to human life, coupled with the low risk use of sUASs to conduct these 

inspections, weighs heavily in favor or granting the exemption. 

Pursuant to 14 C.F.R. 11.35, NTI requests confidential treatment for certain information 

provided with this request for exemption. Specifically, NTI is submitting its proprietary user manual and training syllabus under separate cover as Exhibits 19 and 20. It requests that the information contained in those exhibits not be made public because they are trade secrets whose disclosure would harm NTI. They are valuable commercial data that is not publically available and are protected from release under the Freedom oflnformation Act 5 U.S.C. 552(b)(4). 

For your ease in reviewing this petition, please refer to the table of contents which begins 

on page 2. If we can provide any additional information to assist your understanding or review of this document, please do not hesitate to contact us at 605-334-0005 or via e-mail at 

mark@hwalaw.com. Thank you. 

Best regards, 

Mark A. Ekse 

MAE:ch