UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

REUBEN N. BRAY

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 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 TBS DISCOVERY PRO QUADCOPTER AND TAROT FY 680 

HEXACOPTER UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on October 10, 2015 

Reuben N. Bray

9112 NE 37th Ave

Vancouver, Washington 98665

(503) 380-4616

ReubenNBray@gmail.com
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TABLE OF CONTENTS

Page 

GLOSSARY OF ABBREVIATIONS...................................................................................3 

SUMMARY...........................................................................................................................4 

INTRODUCTION AND INTERESTS OF PETITIONER....................................................4 

BACKGROUND....................................................................................................................5 

BASIS FOR PETITION.........................................................................................................6 

NAME AND ADDRESS OF PETITIONER.............................................................8 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH REUBEN N. BRAY 

SEEKS EXEMPTION ..............................................................................................8 

THE EXTENT OF RELIEF REUBEN N. BRAY SEEKS AND THE REASON 

REUBEN N. BRAY SEEKS THE RELIEF ...........................................................12 

THE REASONS WHY GRANTING REUBEN N. BRAY’S REQUEST WOULD 

BE IN THE PUBLIC INTEREST ..........................................................................16 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY..........................................................................19 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......33 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT REUBEN N. BRAY’S REQUEST ........................34 

CONCLUSION....................................................................................................................35 

APPENDICES........................................................................................37
3

GLOSSARY OF ABBREVIATIONS

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 Modernization and Reform Act of 2012 (FMRA) Section 333

VSO Visual Safety Observer

SOP Standard Operating Procedures

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
4

SUMMARY

Reuben N. Bray seeks exemption from the requirements of 14 C.F.R §§ 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), to operate an Unmanned Aircraft System pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit 

Reuben N. Bray to operate an Unmanned Aircraft System (UAS) for the commercial 

purpose of conducting aerial video and photography of construction sites, real estate, 

agriculture, search and rescue, structural inspection and landscape over certain areas of the 

United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

I provide my clients with aerial photo and video. I have over 10 years of professional video 

and photography. I have over 6 years recreational/hobby RC experience in fixed wing and 

VTOL flying. I have had hundreds of hours of experience of safe flying. My understanding 

of aviation safety, airspace and altitude regulations make my operations of drone safety at 

an elevated level of respect. My objective of aerial video and photography operations is to 

provide high quality imaging for a variety of commercial, public, and residential uses, 

specifically targeting:

 Real-estate 

 Construction sites before and after

 Aerial	acquisitions	used	for	inspections	of	public	and	private	structures.

 Agriculture inspection

 Special event coverage

 Increase public knowledge of UAS and promote safe UAS operations

 Search and Rescue operations

 Public safety operations
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BACKGROUND

Unmanned Aircraft Systems: TBS Discovery Pro and Tarot FY 680

Reuben N. Bray seeks an exemption to operate for compensation or hire within the 

NAS. TBS Discovery Pro and Tarot FY 680 are vertical takeoff and landing (VTOL) 

Unmanned Aircraft System (UAS) with a Ground Control Station (GCS) utilizing 

electronic tablet or smart phone systems. TBS Discovery Pro and Tarot FY 680 both 

weight far less than the maximum 55 lb limitation and fly far less than the 100 mph 

limitation. The TBS Discovery Pro UAS is equipped with four main rotors; driven by

Lithium Polymer battery powered electric motors. The Tarot FY 680 UAS is equipped

with six main rotors; driven by Lithium Polymer battery powered electric motors.
6

BASIS FOR PETITION

Petitioner, Reuben N. Bray, pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator to commercially operate the TBS Discovery Pro and Tarot FY 

680, UAS in the National Airspace System (NAS), and for an exemption from the 

requirements of 14 C.F.R §§ 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). 

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

with the unmanned aircraft and its operation, Reuben N. Bray’s TBS Discovery Pro and 

Tarot FY 680 UAS meets the conditions of FMRA Section 333 and therefore, will not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, Reuben N. Bray requests relief from Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for 

maintenance that only apply to aircraft with an airworthiness certificate. 

Reuben N. Bray submits that the requested relief is proper since an equivalent level 

of safety will be ensured. Reuben N. Bray will use experienced personnel or technicians to 

perform maintenance, alterations, or preventive maintenance on the UAS using the 

methods, techniques, and practices prescribed in the operating documents (i.e., Monthly

Maintenance Log, and Instruction Manual). Furthermore, Reuben N. Bray will document 

and maintain all maintenance records for the TBS Discovery Pro and Tarot FY 680 UAS. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot 

privileges and limitations: Pilot in command, is requested by Reuben N. Bray to the extent 

necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level 
7

certificate, as well as an airman medical certificate, and who has demonstrated, by meeting 

minimum flight- hour and currency requirements, that the PIC is able to safely operate the 

TBS Discovery Pro and Tarot FY 680 UA in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures. 

Reuben N. Bray seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the TBS Discovery Pro and Tarot FY 680 UAS do not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Reuben 

N. Bray submits that he will ensure that the TBS Discovery Pro and Tarot FY 680 UAS is 

in an airworthy condition, prior to every flight, by determining that the UASs are in 

compliance with the operating documents (i.e., Monthly Maintenance Log, and Instruction 

Manual), and that the aircraft is in a condition for safe flight. 

Reuben N. Bray also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the TBS Discovery Pro and Tarot FY 680 UAS will not have 

a typical barometric altimeter onboard. However, altitude information of the TBS 

Discovery Pro and Tarot FY 680 UAS will be provided to the PIC via Global Positioning 

System (GPS) equipment and radio communications telemetry data link, which downlinks 

from the UAS to the GCS for active monitoring of the flight path. This altitude 

information, combined with Reuben N. Bray operation of the TBS Discovery Pro and 

Tarot FY 680 UAS within visual line of sight, at or below 400 feet AGL, will ensure a 

level of safety equivalent to Section 91.121. 

Additionally, Reuben N. Bray seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Reuben N. Bray

submits that safety will not be affected by operation of the TBS Discovery Pro and Tarot 
8

FY 680 UAS during daylight hours in visual meteorological conditions (VMC) under 

visual flight rules (VFR), with battery power to fly for a total duration of approximately 10

minutes.

In accordance with 14 C.F.R. § 11.81, Reuben N. Bray provides the following 

information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

Reuben N. Bray

9112 NE 37th Ave

Vancouver, Washington 98665

ReubenNBray@gmail.com

(503) 380-4616

B. The Specific Sections Of 14 C.F.R. From Which Reuben N. Bray Seeks Exemption. 

1. Reuben N. Bray Seeks Exemption From The Requirements Of Section 

61.113(a) And (b). 

Section 61.113, 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. 

2. Reuben N. Bray Seeks Exemption From The Requirements Of Section 

91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the 

following: 
9

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

3. Reuben N. Bray Seeks Exemption From The Requirements Of Section 

91.121. 

Section 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. 

4. Reuben N. Bray Seeks Exemption From The Requirements Of Section 

91.151(b).

Section 91.151, 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. 

5. Reuben N. Bray Seeks Exemption From The Requirement Of Section 

91.405(a).

Section 91.405, 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[.] 
10

6. Reuben N. Bray Seeks Exemption From The Requirements Of Section 

91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), 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[.] 

7. Reuben N. Bray Seeks Exemption From The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2). 

Section 91.409, 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 --

(1) An annual inspection in accordance with part 43 of this chapter and has 

been approved for return to service by a person authorized by § 43.7 of this 

chapter; or 

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

with part 21 of this chapter. 

8. Reuben N. Bray Seeks Exemption From The Requirements Of Sections 

91.417(a) And 91.417(b). 

Section 91.417, 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 
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(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. 

(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. 

C. The Extent Of Relief Reuben N. Bray Seeks And The Reason Reuben N. Bray

Seeks The Relief. 
12

1. Extent Of Relief Reuben N. Bray Seeks And The Reason Reuben N. Bray

Seeks Relief From Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and 

limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a 

private pilot or higher level certificate, as well as a current and valid airman medical 

certificate, and who has met certain flight-hour and currency requirements, to conduct the 

proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) 

state that 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. 

As set forth more fully below, Reuben N. Bray submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the TBS Discovery

Pro and Tarot FY 680 UAS unless that PIC has met certain flight-hour and currency

requirements, demonstrating that the PIC is able to safely operate either the TBS 

Discovery Pro and Tarot FY 680 in a manner consistent with the operations specifications 

as described in this exemption, including evasive and emergency maneuvers, as well as 

maintaining appropriate distances from people, vessels, vehicles and structures.

Further, Reuben N. Bray submits that all flights of the TBS Discovery Pro and 

Tarot FY 680 UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be 

incidental to Reuben N. Bray’s business; and (2) will not carry passengers or property for 

compensation or hire. 

2. Extent Of Relief Reuben N. Bray Seeks And The Reason Reuben N. Bray

Seeks Relief From Section 91.7(a). 
13

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow Reuben N. Bray to determine that the TBS Discovery Pro and 

Tarot FY 680 UAS is in airworthy condition prior to every flight by ensuring that the UAS 

is in compliance with the operating documents (i.e., the Reuben N. Bray Aerial Operations 

Manual, Monthly Maintenance Log, and Instruction Manual). 

Reuben N. Bray seeks the requested relief because the TBS Discovery Pro and 

Tarot FY 680 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. 

Part 21, Subpart H. Therefore, Reuben N. Bray will ensure that the TBS Discovery Pro and 

Tarot FY 680 UAS are in airworthy condition based upon its compliance with the 

operating documents (i.e., Monthly Maintenance Log, and Instruction Manual) prior to 

every flight, and further, determine that the aircraft are in condition for safe flight, as stated 

in the conditions and limitations below.

3. Extent Of Relief Reuben N. Bray Seeks And The Reason Reuben N. Bray

Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow 

flight operations of the TBS Discovery Pro and Tarot FY 680 UAS, which utilize a 

barometric pressure sensor, GPS equipment, and a radio communications telemetry data 

link to downlink altitude information from the UA to the PIC at the ground control station 

(GCS). Since the FAA requires that any altitude information concerning UAS operations 

be reported to air traffic control (ATC) in feet above ground level (AGL), Reuben N. Bray

seeks the requested relief because the TBS Discovery Pro and Tarot FY 680 UAS altimeter 

may be set on the ground to zero feet AGL, rather than the local barometric pressure or 

field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 

91.121 is sought to the extent necessary to comply with the applicable conditions and 
14

limitations stated below. As more fully set forth herein, an equivalent level of safety will 

be maintained since the TBS Discovery Pro and Tarot FY 680 UAS is equipped with a 

barometric pressure sensor and GPS equipment, which automatically ensures that a ground 

level pressure setting will be established prior to each flight, and provides the PIC with 

altitude information of the UA on the heads-up display of the GCS. 

4. Extent Of Relief Reuben N. Bray Seeks And The Reason Reuben N. Bray

Seeks Relief From Section 91.151(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR 

conditions, is requested to the extent required to allow flights of the battery powered TBS 

Discovery Pro and Tarot FY 680 UAS during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), for a total duration of 10 minutes to the 

first point of intended landing and, assuming normal cruising speed, to fly after that for at 

least 5 minutes. Reuben N. Bray seeks the requested relief because without an exemption 

from Section 91.151(b), the flight time duration of the battery powered TBS Discovery Pro 

and Tarot FY 680 UAS will severely constrain the practicality of any aerial video or still 

photo flight operations that Reuben N. Bray proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the TBS Discovery

Pro and Tarot FY 680 UAS, operating documents, and Reuben N. Bray proposed operating 

limitations, ensure that Reuben N. Bray will safely operate the battery powered TBS 

Discovery Pro and Tarot FY 680 UAS during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a 

total duration of 10 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 5 minutes.

5. Extent Of Relief Reuben N. Bray Seeks And The Reason Reuben N. Bray

Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

And 91.417(a) & (b). 
15

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) 

only apply to aircraft with an airworthiness certificate, Reuben N. Bray requests relief from 

these Sections because the TBS Discovery Pro and Tarot FY 680 UAS do not require 

airworthiness certificates. As set forth more fully below, the TBS Discovery Pro and Tarot 

FY 680 UAS meet the conditions of FMRA Section 333 for operation without an 

airworthiness certificate. Accordingly, Reuben N. Bray will use trained technicians to 

perform maintenance, alterations, or preventive maintenance on the UASs using the

methods, techniques, and practices prescribed in the UAS operating documents (i.e., the 

Reuben N. Bray Aerial Operations Manual, Monthly Maintenance Log, and Instruction 

Manual). Furthermore, Reuben N. Bray will document and maintain all maintenance 

records for the TBS Discovery Pro and Tarot FY 680 UAS. 
16

D. The Reasons Why Granting Reuben N. Bray Request Would Be In The Public 

Interest; That Is, How It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing Reuben N. 

Bray to safely, efficiently, and economically perform aerial video and photography of 

construction sites, real estate, and landscape over certain areas of the United States. 

Additionally, use of the TBS Discovery Pro and Tarot FY 680 UAS will decrease 

congestion of the NAS, reduce pollution, and provide significant benefits to the economy. 

Notably, the benefits of Reuben N. Bray proposed operation of the TBS Discovery Pro and 

Tarot FY 680 UAS will be realized without implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The TBS Discovery Pro and Tarot FY 680 UAS is battery powered and serve as a 

safe, efficient, and economical alternative to the manned aircraft traditionally utilized to 

obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial 

acquisitions, an exemption allowing the use of a TBS Discovery Pro and Tarot FY 680 

UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air 

pollution, as well as increase the safety of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. The 

TBS Discovery Pro and Tarot FY 680 UAS does not require an airport to takeoff or land. 

Likewise, a reduction of manned aircraft conducting aerial video and photography 

missions would result in fewer aircraft that must be handled by air traffic control during 

the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The TBS 

Discovery Pro and Tarot FY 680 UAS. 
17

Conducting aerial acquisitions with the TBS Discovery Pro and Tarot FY 680 

UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the 

levels of air and noise pollution generated during traditional aerial video and still 

photography flight operations. By using battery power and electric motors, the TBS 

Discovery Pro and Tarot FY 680 UAS produce no air pollution, and is the most viable 

environmentally conscious alternative to the cabin class, six cylinder internal combustion 

engine aircraft that are typically utilized for aerial video and photography, while burning 

approximately 20-30 gallons per hour of leaded aviation fuel. TBS Discovery Pro and 

Tarot FY 680 UAS, while reducing the carbon footprint of aerial acquisitions, also 

eliminates noise pollution, as the UASs are propelled by battery powered electric motors, 

rather than an internal combustion engine. 

By using the TBS Discovery Pro and Tarot FY 680 UAS to perform aerial 

acquisitions, the substantial risk to life and property in the air and on the ground, which is 

usually associated with traditional manned aircraft flight operations, will be substantially

reduced or completely eliminated. Aside from the lack of flight crew members located 

onboard the aircraft, the TBS Discovery Pro and Tarot FY 680 UAS (weighing 

approximately 5-7lbs , at their maximum gross weights with lengths of 20 inches, widths 

of 20 inches, and with no fuel on board), has less physical potential for collateral damage 

to life and property on the ground, and in the air, compared to the manned aircraft that 

typically conduct similar operations (weighing approximately 6,000 pounds with a 

wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The TBS 

Discovery Pro and Tarot FY 680 UAS Will Benefit The Economy. 

In addition to being safe and efficient, the TBS Discovery Pro and Tarot FY 680 

UAS are also an economical alternative to using manned aircraft to conduct similar aerial 
18

operations. As such, operation of the TBS Discovery Pro and Tarot FY 680 UAS will 

allow United States based companies, like Reuben N. Bray, to remain competitive and 

contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel 

and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded 

aviation fuels, U.S. owned and operated companies must adopt new and alternative

technology in order to remain competitive. Operating the battery powered TBS Discovery

Pro and Tarot FY 680 UAS is one such technology that not only allows companies greater 

operational flexibility compared to manned aircraft, but provides such flexibility without 

the high operational cost of a traditional manned aircraft. 

By operating the TBS Discovery Pro and Tarot FY 680 UAS, companies such as 

Reuben N. Bray, can remain competitive and profitable, and therefore, provide greater job 

stability to employees and contractors, which will ultimately contribute to growth of the 

U.S. economy. Improved financial performance of U.S. companies, through commercial 

use of the TBS Discovery Pro and Tarot FY 680 UAS, provides a stable workforce that 

increases consumer spending; improves local, state, and federal tax revenues; and allows 

companies to invest in research and development in order to remain competitive both in 

the United States and abroad. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, Reuben N. Bray proposed operation of the TBS Discovery Pro and Tarot FY 680 

UAS will not implicate any privacy issues. Specifically, the TBS Discovery Pro and Tarot 

FY 680 UAS will be operated only in compliance with operating documents (i.e., the 

Reuben N. Bray’s Aerial Operations Manual, Monthly Maintenance Log, and Instruction 

Manual) which requires property owner involvement as well as local law enforcement 
19

notification, and in accordance with the Federal Aviation Regulations, including the 

minimum altitude requirements of 14 C.F.R. § 91.119. 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, 

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That

Provided By The Rule From Which Reuben N. Bray Seeks Exemption. 

1. Reasons Why The TBS Discovery Pro and Tarot FY 680 UAS Meet The 

Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) 

Section 333. 

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

with the unmanned aircraft and its operation, Reuben N. Bray operation of the TBS 

Discovery Pro and Tarot FY 680 UAS meet the conditions of FMRA Section 333, and will 

not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security. 

Specifically, FMRA Section 333 states the following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not 

later than 180 days after the date of enactment of this Act, the Secretary of 

Transportation shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the plan 

and rulemaking required by section 332 of this Act or the guidance required by 

section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their 

size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create 

a hazard to users of the national airspace system or the public or pose a 

threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1). 
20

(c) Requirements for Safe Operation.--If the Secretary determines under this 

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace system. 

In seeking this exemption, Reuben N. Bray submits that the TBS Discovery Pro 

and Tarot FY 680 UAS can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the DJI Phantom 3 Professional and DJI Inspire 

1 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations. 

a. The Specifications Of The TBS Discovery Pro and Tarot FY 680 UAS

Demonstrate Its Safe Characteristics.

The TBS Discovery Pro and Tarot FY 680 UAS do not create a hazard to users of 

the NAS or the public, or otherwise pose a threat to national security considering its size, 

weight, speed, and operational capability. 

i. Technical Specifications Of The TBS Discovery Pro and Tarot FY 

680 UAS. 

The technical specifications of the TBS Discovery Pro and Tarot FY 680 UAS are 

set forth by the TBS Discovery Pro and Tarot FY 680 UAS Specifications and Data Sheet, 

attached hereto as Exhibit A. 

ii. The TBS Discovery Pro and Tarot FY 680 UAS Autonomous Flight 

And Navigation Modes Enable The UASs To Remain Within A 

Defined Operational Area. 

The TBS Discovery Pro and Tarot FY 680 UAS may be operated in both manual 

and fully autonomous flight modes. A complete description of the flight and navigational 

modes of the TBS Discovery Pro and Tarot FY 680 UAS is provided in the User Manuals.

iii. The TBS Discovery Pro and Tarot FY 680 UAS Is Designed For 

Automatic Return To Home Point Or Hover In The Event Of Loss 

Of The Control Link Or Navigation. 

When the Control Link is lost, the TBS Discovery Pro and Tarot FY 680 UAS will 

remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the TBS Discovery
21

Pro and Tarot FY 680 UAS do not reacquire control link data from the GCS, the UASs 

will assume that the Control Link is lost and the UASs will return to the home position 

(i.e., RTL failsafe mode) via GPS, and will descend to the takeoff position and shutdown. 

A complete description of the Failsafe Functions of the TBS Discovery Pro and 

Tarot FY 680 UAS are set forth in the TBS Discovery Pro and Tarot FY 680 UAS User 

Manuals, 

iv. TBS Discovery Pro and Tarot FY 680 UAS GCS And Its Operation.

A complete description of the operation and specifications of the TBS Discovery

Pro and Tarot FY 680 UAS GCS and flight control software is provided in the User 

Manual.

b. Flight Operations Of TBS Discovery Pro and Tarot FY 680 UAS Are 

Limited To The Line Of Sight Of the Pilot in Command With A Safety 

Observer. 

Reuben N. Bray will utilize, a safety observer, at all times, during the entire 

duration of the flight. Restricting the flight to line of sight at all times. 

c. Flights Of TBS Discovery Pro and Tarot FY 680 UAS Will Be Conducted 

Pursuant To Specific Operating Limitations. 

In seeking this exemption, Reuben N. Bray proposes to commercially operate TBS 

Discovery Pro and Tarot FY 680 UAS for the special purpose of conducting aerial video 

and photography over certain areas of United States, pursuant to the following specific 

operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following 

aircraft described in the operating documents, rotorcraft UASs weighing less 

than 55 pounds maximum gross weight: TBS Discovery Pro and Tarot FY 680 

UAS. Proposed operations of any other aircraft will require a new petition or a 

petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations 

for the purpose of aerial video and photography. 

3. The UASs may not be flown at an indicated airspeed exceeding 100 mph.
22

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

level (AGL), as indicated by the procedures specified in the operating 

documents unless a special request is made and approved by ATC. All altitudes 

reported to ATC must be in feet AGL. 

5. The UASs must be operated within visual line of sight (VLOS) of the PIC, and 

the VSO 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. 

6. All operations must utilize a safety observer (SO). The SO may be used to satisfy

the VLOS requirement as long as the PIC always maintains VLOS capability. 

The SO 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 SO can perform the 

functions prescribed in the operating documents. 

7. The SO must not perform any other duties beyond assisting the PIC with seeing 

and avoiding other air traffic and other ground based obstacles/obstructions and 

is not permitted to operate the camera or other instruments. 

8. The operating documents and the grant of exemption must be accessible during 

UAS operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations contained in the grant 

of exemption and the procedures outlined in the operating documents, the 

conditions and limitations contained in the grant of exemption 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 upon request. 

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

extension or amendment to the grant of exemption. If the operator determines 

that any update or revision would affect the basis upon which the FAA granted 

the exemption, then the operator must petition for 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. 

9. Prior to each flight the PIC must inspect the UAS to ensure that it is in a 

condition for safe flight. 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. The Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records.

10. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical 
23

component, must undergo a functional test flight. The PIC who conducts the 

functional test flight must make an entry in the aircraft records. 

11. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the 

relevant sections of the operating documents. 

12. The operator must follow the UAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 

13. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/overhaul component parts 

must be noted in the aircraft records, including total time in service, description 

of work accomplished, and the signature of the authorized person returning the 

UAS to service. 

14. Each UASs operated under this exemption must comply with all manufacturer 

Safety Bulletins. 

15. The authorized person must make an entry in the aircraft record of the 

corrective action taken against discrepancies discovered between inspections. 

16. The operator may not permit any PIC to operate unless the PIC meets the 

operator’s qualification criteria and demonstrates the ability to safely operate the 

UAS in a manner consistent with how the UAS will be operated under the 

exemption, including evasive and emergency maneuvers and maintaining 

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

qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 

61.51(b). Flights for the purposes of training the operator’s PICs are permitted 

under the terms of the 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 C.F.R. § 91.119.

17. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 

1.1. All operations must be conducted under visual meteorological conditions 

(VMC). If flight at night is required, a special request will be made at the FAA 

office closest to proposed area of operations. Flights under special visual flight 

rules (SVFR) are not authorized. 

18. The UAS may not operate within 5 miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained, and the operation is 

conducted in accordance with a NOTAM as required by the operator’s COA.

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

the Administrator upon request. 
24

19. The UAS 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. 

20. If the UAS loses communications or loses its GPS signal, it must return to a 

pre- determined location within the planned operating area and land or be 

recovered in accordance with the operating documents. 

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

emergencies in accordance with the operating documents. 

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

forecast weather conditions) there is enough power to fly at normal cruising 

speed to the intended landing point and land the UAS with 25% battery power 

remaining. 

23. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be 

available to the PIC at the Ground Control Station of the UAS any time the 

UAS is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request. 

24. The UAS must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

25. Flight operations must be conducted at least 100 feet from all nonparticipating 

persons (persons other than the PIC, VSO, operator trainees or essential 

persons), vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UAS 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 100 feet of the UAS, flight operations must 

cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted 

permission 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, and; 

c. Operations nearer to the PIC, VSO, operator trainees or essential persons 

do not present an undue hazard to those persons per § 91.119(a). 

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

with permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted via written or oral authorization.
25

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) 

And (b) Would Not Adversely Affect Safety.

Reuben N. Bray submits that the equivalent level of safety established by Section 

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the TBS 

Discovery Pro and Tarot FY 680 UAS unless that PIC has demonstrated, by meeting 

minimum flight-hour and currency requirements, that the PIC is able to safely operate the 

TBS Discovery Pro and Tarot FY 680 UAS in a manner consistent with the exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures. 

Considering Reuben N. Bray’s proposed area of operations, and the operating 

limitations set forth-above; the parallel nature of private pilot aeronautical knowledge 

requirements to those of commercial pilot requirements (See Exemption No. 11062); and 

the airmanship skills necessary to safely operate the TBS Discovery Pro and Tarot FY 680 

UAS, Reuben N. Bray submits that the additional manned airmanship experience of a 

commercially certificated pilot would not correlate to the airmanship skills necessary for 

Reuben N. Bray specific proposed flight operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to 

UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). 

Reuben N. Bray will not allow any PIC to operate the TBS Discovery Pro and 

Tarot FY 680 UAS unless that PIC has demonstrated, by meeting minimum flight-hour 

requirements or the TBS Discovery Pro and Tarot FY 680 UAS training and currency

requirements, that the PIC is able to safely operate the TBS Discovery Pro and Tarot FY 

680 UAS in a manner consistent with this exemption, including evasive and emergency
26

maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent 

with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS multirotor craft pilot (with a 

minimum of 5 hours of those hours as a UAS pilot operating the same make and model of 

UAS to be used for operations under the exemption). In addition to the hour requirements, 

the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency

purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight 

experience that was obtained in compliance with applicable regulations will ensure an 

equivalent level of safety during Reuben N. Bray’s proposed operations. The 

Administrator has held that prior documented flight experience that was obtained in 

compliance with applicable regulations would ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for 

the purpose of motion picture filming (or similar operations), the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of 

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS 

pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the 

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

operating the same make and model of UAS to be used for operations under the 

exemption. For clarification, the FAA considers these minimum hour requirements 

to be inclusive rather than additive; i.e. 5 hours make and model time may be 

included in the 10 hours of multi-rotor time and the 10 hours may be included in 

the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the 

PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for 

currency purposes). The FAA finds that at a minimum, the flight-hour requirements 

in Exemption No. 11062 are appropriate to practice and build proficiency in the 

skills necessary to safely conduct the petitioner’s proposed operations. The FAA 

also finds that prior documented flight experience that was obtained in compliance 

with applicable regulations would satisfy this requirement. Training, proficiency, 

and experience-building flights can also be conducted under the grant of exemption 

to accomplish the required flight time. During training, proficiency, and 

experience-building flights the PIC is required to operate the UA with appropriate 

distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 
27

Accordingly, Reuben N. Bray will ensure safe operations by not allowing any PIC 

to operate the TBS Discovery Pro and Tarot FY 680 UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is 

able to safely operate the TBS Discovery Pro and Tarot FY 680 UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) 

Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained 

because prior to every flight, Reuben N. Bray will ensure that the TBS Discovery Pro and 

Tarot FY 680 UAS is in an airworthy condition based upon the UAS’s compliance with its 

operating documents and as stated in the conditions and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific 

to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained 

because the altitude information of the TBS Discovery Pro and Tarot FY 680 UAS will be 

provided to the PIC via GPS equipment and a radio communications telemetry data link, 

which downlinks from the UAS to the GCS for active monitoring of the flight path and 

altitude. This altitude information, combined with Reuben N. Bray’s operation of the TBS 

Discovery Pro and Tarot FY 680 UAS within visual line of sight, at or below 400 feet 

AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information 
28

will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a 

zero altitude initiation point is automatically established by the UASs at ground level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) 

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the TBS 

Discovery Pro and Tarot FY 680 UAS; (2) the limitations on the proposed flight 

operations; and (3) the location of the proposed flight operations. Accordingly, Reuben N. 

Bray will ensure that it will safely operate the battery powered TBS Discovery Pro and 

Tarot FY 680 UAS during daylight hours in VFR conditions, with enough battery power to 

fly for a total duration of 10 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the TBS 

Discovery Pro and Tarot FY 680 UAS; the limitations on the proposed flight operations; 

and the location of the proposed operations, will ensure an equivalent level of safety 

established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the 

TBS Discovery Pro and Tarot FY 680 UAS provide audible and visual warnings to the PIC 

at the GCS when the UASs experiences low battery voltage, the first warning occurring at 

approximately 33% remaining battery power, and again at approximately 10% remaining 

battery power. At the critically low battery level, the TBS Discovery Pro and Tarot FY 680 

UAS will descend and land automatically with sufficient battery power to land safely. 
29

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief 

from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would 

Not Adversely Affect Safety. 

In seeking this exemption, Reuben N. Bray submits that the equivalent level of 

safety with regard to the regulatory maintenance and alteration requirements established by 

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met 

because Reuben N. Bray will use trained technicians to perform maintenance, alterations, 

or preventive maintenance on the UASs using the methods, techniques, and practices 

prescribed in the operating documents (i.e., the Reuben N. Bray Aerial Operations Manual, 

Monthly Maintenance Log, and TBS Discovery Pro and Tarot FY 680 UAS Instruction 

Manual). Furthermore, Reuben N. Bray will document and maintain all maintenance 

records for the TBS Discovery Pro and Tarot FY 680 UAS. 

Since the TBS Discovery Pro and Tarot FY 680 UAS will be inspected as 

prescribed by the operating documents, Reuben N. Bray will maintain the equivalent level 

of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). 

Likewise, the exemption sought will not adversely affect safety because Reuben N. 

Bray will use trained technicians to perform maintenance, alterations or preventive 
30

maintenance on the UAS using the methods, techniques, and practices prescribed by the 

operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 

TBS Discovery Pro and Tarot FY 680 UAS will be performed by trained technicians. 

Maintenance will be documented and maintained utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is 

not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. 

In consideration of Reuben N. Bray proposed operating limitations, the operating 

documents, and the technical aspects of the TBS Discovery Pro and Tarot FY 680 UAS, 

Reuben N. Bray submits that safety will not be adversely affected by granting exemption 

from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) 

and (b). The FAA has previously granted relief specific to UAS in circumstances similar, 

in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 

11156, 11157, 11158, 11159, 11160, 11161). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Reuben N. Bray requests that 

the FAA prescribe special conditions for the intended operation of the TBS Discovery Pro 

and Tarot FY 680 UAS, which contain such safety standards that the Administrator finds 

necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, 
31

Subpart H, and 14 C.F.R §§ 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). Such special conditions will 

permit safe operation of the UASs for the limited purpose of conducting aerial video and 

photography over certain areas of the United States for compensation or hire. FMRA 

Section 333 sets forth the requirements for considering whether a UAS will create a hazard 

to users of the NAS or the public, or otherwise pose a threat to national security; and 

further, provides the authority for such UAS to operate without airworthiness certification 

in accordance with any requirements that must be established for the safe operation of the 

UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the TBS Discovery Pro and Tarot FY 680 UAS, since the 

airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate 

safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, 

entitled Special Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of a novel or unusual design feature of the aircraft, aircraft engine or 

propeller, he prescribes special conditions and amendments thereto for the product. 

The special conditions are issued in accordance with Part 11 of this chapter and 

contain such safety standards for the aircraft, aircraft engine or propeller as the 

FAA finds necessary to establish a level of safety equivalent to that established in 

the regulations. 

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA 

may prescribe special conditions for Reuben N. Bray intended operation of the TBS 

Discovery Pro and Tarot FY 680 UAS, which contain such safety standards that the 

Administrator finds necessary to establish a level of safety equivalent to that established by 
32

14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 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).
33

F. A Summary That Can Be Published In The Federal Register, stating: The Rules 

From Which Reuben N. Bray Seeks Exemption: 

Reuben N. Bray seeks exemption from the requirements of 14 C.F.R Sections 

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). 

A Brief Description Of The Nature Of The Exemption Reuben N. Bray Seeks: 

This exemption will permit Reuben N. Bray to commercially operate an Unmanned

Aircraft System (UAS) for the purpose of conducting aerial video and photography 

over certain areas of the United States.
34

G. Any Additional Information, Views, Or Arguments Available To Support Reuben 

N. Bray’s Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain 

UAS may operate safely in the NAS. As such, Reuben N. Bray’s request for exemption 

may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as 

set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will 

create a hazard to users of the NAS or the public, or otherwise pose a threat to national 

security; and further, provides the authority for such UAS to operate without airworthiness 

certification. 

As discussed in detail above, Reuben N. Bray will operate the TBS Discovery Pro 

and Tarot FY 680 UAS safely in the NAS, without creating a hazard to users of the NAS, 

or the public, or otherwise pose a threat to national security. 
35

CONCLUSION

As set forth herein, Reuben N. Bray seeks an exemption pursuant to 14 C.F.R. § 

11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), 

which will permit safe operation of the TBS Discovery Pro and Tarot FY 680 UAS 

commercially, without an airworthiness certificate, for the limited purpose of conducting 

aerial video and photography over certain areas of the United States. By granting this 

Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA 

Modernization and Reform Act of 2012, while also advancing the interests of the public, 

by allowing Reuben N. Bray to safely, efficiently, and economically operate the TBS 

Discovery Pro and Tarot FY 680 UAS commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, Reuben N. Bray respectfully

requests that the Administrator grant this Petition for an exemption from the requirements 

of 14 C.F.R Sections 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), and permit Reuben N. Bray to operate the TBS 

Discovery Pro and Tarot FY 680 UAS commercially for the purpose of conducting aerial 

video and photography over certain areas of the United States.

Dated: October 10, 2015

Respectfully submitted,

Reuben N. Bray 

9112 NE 37th Ave 

Vancouver, Washington 98665

(503) 380-4616

ReubenNBray@gmail.com
36

Appendices:

A – TBS Discovery Pro and Tarot FY 680 UAS Specifications Data Sheet

B – Monthly Maintenance Log
37

APPENDIX – A

TBS Discovery Pro and Tarot FY 680 UAS

PROFESSIONAL TECHNICAL SPECIFICATIONS

Reuben N. Bray only utilizes safe and reliable UASs equipment. TBS Discovery Pro and 

Tarot FY 680 UAS is an industry leader in small UAS production. TBS Discovery Pro 

and Tarot FY 680 UAS are equip with 3DR APM 2.6 AUTOPILOT, which is ground 

breaking software enabling the user to set parameters which will not allow flight into 

controlled airspace. Parameters can also be set to limit flight to no higher than a 

predetermined and set altitude as well as limit flight to a predetermined and set 

distance. In addition, DJI software provides real-time altitude and location information 

to the PIC via the linked monitor (smart phone/tablet devices)

1.1 TBS Discovery Pro UAS

1.1.0 Aircraft

1.1.1 Supported Battery – 4500mAH 4S Lithium Polymer Battery

1.1.2 All Up Weight (Camera, Battery & Propellers Included) – 4.5 lbs

1.1.3 Hover Accuracy (Ready to Fly) – Vertical: 2ft; Horizontal: 1ft

1.1.4 Asymmetric spider quadcopter Airframe: Reinforced black fiberglass 

1.1.5 Propellers: 10x5-inch 

1.1.6 Gimbal : 2-axis, roll and tilt 

1.2.0 Camera GoPro Hero 4 Black

 1.2.1 Resolution – 3840x2160

1.2.2 HD Video Recording – 1080p24

1.2.3 Recording Field of View - 1100/850

1.3.0 Transmitter

1.3.1 Operating Frequency – 5.728GHz – 5.85GHz

1.3.2 Communication Distance (unobstructed) – FCC Compliance: 800m

1.3.3 Receiver Sensitivity (1%PER) - -93dBm

1.3.4 Transmitter Power – FCC Compliance: 100mW

1.3.4 Working Voltage – 9.7V

2.1 Tarot FY 680 UAS

2.1.0 Aircraft

2.1.1 Supported Battery – 5000mAH 4S Lithium Polymer Battery

2.1.2 All Up Weight (Camera, Battery & Propellers Included) – 8 lbs

2.1.3 Hover Accuracy (Ready to Fly) – Vertical: 2ft; Horizontal: 1ft

2.1.4 Symetric Hexacopter Airframe: Reinforced black fiberglass

2.1.5 Propellers: 12x5-inch 

2.1.6 Gimbal : 3-axis, yaw, roll and tilt 

2.2.0 Camera GoPro Hero 4 Black

 2.2.1 Resolution – 3840x2160

 2.2.2 HD Video Recording – 1080p24
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1.2.3 Recording Field of View - 1100/850

1.3.0 Transmitter

1.3.1 Operating Frequency – 5.728GHz – 5.85GHz

1.3.2 Communication Distance (unobstructed) – FCC Compliance: 800m

1.3.3 Receiver Sensitivity (1%PER) - -93dBm

1.3.4 Transmitter Power – FCC Compliance: 100mW

1.3.4 Working Voltage – 9.7V
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APPENDIX – B