September 1, 2015

Exemption No. 12704

Regulatory Docket No. FAA–2015–1150

Mr. Carson Wade Lee

President

Turbine Aircraft Logistics, LLC

5715 Oak Hollow Lane

Oviedo, FL 32765

Dear Mr. Lee:

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 letters dated April 13, 2015, and June 28, 2015, you petitioned the Federal Aviation 

Administration (FAA) on behalf of Turbine Aircraft Logistics, LLC (hereinafter petitioner or 

operator) for an exemption. The petitioner requested to operate an unmanned aircraft system 

(UAS) to conduct aerial photography and videography.

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 DJI Inspire 1.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

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

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 
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consideration of the size, weight, speed, and limited operating area associated with the 

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

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

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

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

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1

. The FAA has issued grants of 

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

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

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

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

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

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

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

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

by this exemption is in the public interest.

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

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

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

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

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

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

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

delegated to me by the Administrator, Turbine Aircraft Logistics, LLC 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.
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Conditions and Limitations

In this grant of exemption, Turbine Aircraft Logistics, LLC 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 DJI Inspire 1 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, 
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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.
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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.
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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.
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If this exemption permits operations for the purpose of closed-set motion picture and 

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

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

as documented in this grant of exemption.

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

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

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

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

must include at least the following:

a. Dates and times for all flights;

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

under this grant of exemption;

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

the UAS;

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

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

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

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

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

g. Signature of exemption holder or representative; and

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

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

essential to accomplish the operation.

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

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

exemption holder’s MPTOM.

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

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

parts 45, 47, 61, and 91.
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This exemption terminates on September 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
1

Turbine Aircraft Logistics, LLC

5715 Oak Hollow Ln

Oviedo, FL 32765

386-385-8436

info@turbineaircraftlogistics.com

April 13, 2015 

U.S. Department of Transportation 

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Turbine Aircraft Logistics, LLC’s Petition for Exemption to Operate

Unmanned Aircraft System for Aerial Photography and Filming 

FAA Regulatory Docket 

NAME AND ADDRESS OF PETITIONER

Turbine Aircraft Logistics, LLC

Attn: Carson Wade Lee

5715 Oak Hollow Ln

Oviedo, FL 32765

386-386-8436

info@turbineaircraftlogistics.com
2

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, 

Pub. L. No. 112-95 (2012), 126 Stat. 11 (“Section 333”) and the Federal Aviation 

Administration’s (“FAA”) general exemption authority under 49 U.S.C. § 44701(f), 

Turbine Aircraft Logistics, LLC (“Petitioner or Operator”) hereby petitions for 

exemptions from 14 C.F.R. Part 21, 14 C.F.R. §§ 61.113(a) and (b), 61.133(a), 91.7(a), 

91.9(b)(2), 91.103(b)(1), 91.119(c), 91.121, 91.151, 91.203(a) and (b), 91.405(a), 

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

I. Petition Summary

If granted, this exemption would allow the operator to operate a small UAS (under 55lbs) 

with an attached camera for the purpose of aerial photography and videography. With a 

combination of factors below, the operator is confident that it can operate the UAS in a 

manner equal to the safety standards set forth by the FARs for civilly manned aircraft: 

• Reliability 

• Return to designated point in the event of a lost control link

• Return to designated point automatically with a low battery that is dynamically 

updated depending how far away the UAS is from the designated point

• Low weight

• Slow speed

• No passengers to be carried

• Experience of the crew members

• Stringent maintenance program 

The operator will be operating the UAS for the purpose of providing photographs and 

video as needed to the public for a fee. Bringing more competition to the market place in 

a currently very small industry can be found to be in the public interest and therefor the 

FAA can find good cause to grant the exemption. 

II. Exemptions Requested

The operator is requesting relief from the following FAA regulations:

• FAR part 21 (Certification procedures) 

• FAR 61.113 (a) and (b) (Private pilot privileges and limitations)

• FAR 61.133(a) (Commercial pilot privileges and limitations)

• FAR 91.7(a) (Civil aircraft airworthiness)

• FAR 91.9(b)(2) (Civil aircraft flight manual, markings, placards requirement)

• FAR 91.103(b)(1) (Preflight action)
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• FAR 91.119(c) (Minimum safe altitudes)

• FAR 91.121 (Altimeter settings) 

• FAR 91.151 (Fuel requirements)

• FAR 91.203(a) and (b) (Civil aircraft certifications required)

• FAR 91.405(a) (Maintenance Required)

• FAR 91.409(a)(1) and (a)(2) (Inspections)

III. Operational Procedures to Satisfy Section 333 

1 Unmanned Aircraft System

1.1 The UAS the operator seeks exemption for is manufactured by DJI and the 

model is the Inspire 1. This UAS is the most recent model DJI offers and was 

a highly improved from what was learned from the previous highly popular 

and reliable DJI Phantom series. The DJI Inspire 1 is a 6.47lb multi-rotor (4 

rotors) UAS with approximately 18 minutes of endurance. The Inspire 1’s 

purpose is to carry a small camera as its payload. The Inspire 1 has the ability 

to be controlled by a single crewmember acting as pilot in command by 

wireless remote control on a 2.4GHz band having a transmitting distance of 

2km (1.08nm). 

1.2 The Inspire 1 is equipped with lost link protection (referred to as “Return To 

Home” (RTH) in the Inspire 1 User Manual), allowing the UAS to 

automatically climb vertically to a safe altitude to clear obstacles; then 

proceed to a pre-designated point to automatically land. At anytime the UAS 

and the controller reestablish link, the PIC can cancel the RTH and resume 

control of the UAS. In the event of lost GPS signal, control to the Inspire UAS 

is not lost. Since all operations will be conducted under Visual Line of Sight 

VLOS the PIC can control the aircraft back to a safe location to land. 

1.3 Because the Inspire 1 UAS does not have the endurance to meet the 

requirements of FAR 91.155(b), the operator is requesting exception from this 

regulation and substituted with the following standard: All flights will be 

terminated at a maximum of a 25-minute flight or when the battery level 

reaches 25% (which ever occurs first).

1.4 The operator will register the UAS IAW FAR part 47. The operator’s UAS 

will have identification makings in accordance with FAR 45(c). The Inspire 1 

UAS is too small to practically display registration markings IAW FAR 

45.29(a) though (e). The registration marks will be affixed as large as practical 

IAW FAR 45.29(f).

1.5 The operator is requesting relief from FAR 91.121 because the Inspire 1 UAS 

is not equipped with a standard adjustable barometric altimeter system. The 

Inspire 1 UAS collects altitude information for two sources: GPS and 

barometric aiding. Upon powering one the Inspire 1, the system will reset the 

altitude readout on the controllers base station to 0 feet above ground level 

(AGL). The PIC then will reference the digitally displayed altitude in AGL for 

the duration of the flight.
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1.6 Because of the small size, low weight, slow speed, and limited operating area 

of the Inspire 1 UAS, the operator is requesting relief from CFR part 21(h) 

(airworthiness certificates). The operator has determined that it can operate 

the Inspire 1 UAS to an equivalent level of safety set forth under part 21 of the 

CFRs and meets the requirements set forth in the 333 exemption.

1.7 Prior to flight the Inspire 1 UAS will be determined to be in an airworthy 

condition IAW the pre-flight checklist outlined in appendix A Inspire 1 User 

Manual V1.0 page 49. The operator is requesting exemption from required 

inspections of FAR 91.409(a)(1) and (2) and will adopt the manufactures 

recommended inspections program as outlined in the following paragraph. 

Because the FAA has not established an inspection standard for UAS as have 

been established for manned aircraft under FAR 43.13 appendix D, the 

operator is requesting an exemption from the maintenance scope and detail of 

FAR 43.13 appendix D and replaced with the manufactures recommended 

maintenance program: The operator will inspect and maintain the Inspire 1 

UAS IAW DJI Inspire 1 Maintenance Manual (See appendix B Inspire 1 

Maintenance Manual). The operator will follow the manufactures 

recommended inspection interval to preform comprehensive maintenance of 

the Inspire 1 every 50 flight hours or 200 flights, whichever comes first as 

outlined in the Inspire 1 Maintenance Manual. A FAA certified Airframe & 

powerplant mechanic would preform the above maintenance and inspections. 

1.8 The operator will adopt maintenance record requirements set forth under FAR 

91.417.

1.9 The DJI Inspire UAS operates on the 2.4GHz frequency band for both UAS 

control as well as video downlink. Both the Inspire 1 UAS as well and the 

UAS remote controller comply with part 15 of the FCC rules (see page 

appendix A, page 62 of the DJI Inspire user manual). The Inspire 1 is 

equipped with a vision positioning system along with a sonar system in order 

to be able to fly inside a building and still remain stable. The Inspire 1’s 

primary payload is a small X3 model FC350 camera mounted with a Zenmuse 

X3 gimbal. 

1.10 Refer to appendix A Inspire 1 User Manual V1.0 for more detail on the 

Inspire 1 UAS.

2. Unmanned Aircraft PIC

2.1 The operator has designated Carson Wade Lee, Airline Transport Pilot (ATP) 

as the chief pilot for its UAS operations. Carson currently holds 13 years of 

flight experience with over 4700 flight hours in manned aircraft. Carson holds

an Airline Transport Pilot Certificate for both single and multi-engine land 

aircraft. Carson also holds an Airframe & Powerplant FAA mechanic 

certificate with Inspection Authorization under FSDO-15. Carson also has 2 

years of experience with hundreds of hours with UAS for recreational use. 

Carson has accrued 12 hours as PIC with the DJI Inspire 1 model UAS

2.2 The operator is requesting that the operators chief UAS pilot be allowed to 

designate any UAS pilot with the following experience requirements:
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• Hold a FAA Private Pilot

• Hold a FAA third class medical or higher

• Meets the flight review requirements of FAR 61.56 in manned aircraft 

• Meets the recent flight experience for PIC of FAR 61.57 (UAS takeoff/landings)

• Has accrued 25 hour total time operating UAS

• Has a minimum of 10 hours operating similar model UAS.

• Has a minimum of 5 hours make and model of UAS

• Pass a knowledge and skill test for the UAS developed by the chief UAS pilot 

2.3 The PIC will designate a Visual Observer (VO) prior to any flight to be 

conducted. Any VO to be used by the PIC must be authorized by the UAS 

chief pilot. Further, the VO shall be familiar with UAS operations to the 

extent their designated role as VO requires. The VO will be require to be able 

to communicate with the PIC verbally at all times. 

2.4 It will be the PICs responsibility to review weather conditions, flight battery 

requirements, and UAS performance limitations prior to conducting the flight.

3. UAS Operating Procedures

3.1 All UAS flight operations will be conducted during daylight hours.

3.2 All UAS operations will be conducted in VFR conditions.

3.3 No UAS operation will be conducted with less cloud clearance or visibly then 

is allowed by FAR 91.155. 

3.4 No UAS flight operations will be conducted beyond the visual sight of both 

the PIC and the VO.

3.5 No UAS flight operation will be conducted above a vertical height of 400ft 

AGL.

3.6 NO UAS flight operations will be conducted within highly populated areas.

3.7 The PIC will not fly the UAS at speeds to exceed 50KTS ground speed.

3.8 The PIC will insure that no person, other then those trained and designated by 

the Chief UAS pilot in UAS operations, are within 500ft of horizontal 

distance from the UAS during flight operations or while the rotors are turning.

3.9 The PIC will insure that the UAS in flight comes no closer then 500ft of 

vehicles or structures, with the exception of those that are a part of the filming 

operation. PIC will obtain a signed consent form from the owner or authorized 

representative of any vehicle or structure the UAS in flight will come within 

500ft of.

3.10 Prior to any UAS flight operation the PIC will consult current FAA 

aeronautical sectional charts and airport facility directory to insure that no 

flight operation will come within 5NM of an airport with a control tower, 

3NM of an airport not having an operational control tower but having a 

published instrument approach procedure, 2NM of an airport not having an 

operational control tower or instrument approach procedure, or 2NM of a 

heliport having an instrument approach procedure without having an 

appropriate authorization from the ATC controlling facility and airport 

manager.
6

3.11 PIC will remain clear and yield right of way to all manned aircraft 

operations of all category and classes.

3.12 The PIC prior to conducting UAS flight operations will review current 

aeronautical charts, TFRs, and NOTAMS to insure that no flight operations 

will be conducted within an active restricted area, prohibited area, warning 

area, or TFR. 

3.13 Prior to UAS operations for the motion picture or television industry, the 

operator will comply with regulations set forth in FAA order 8900.1, Volume 

3, chapter 8, section 1 (Certificate of Waiver for Motion Picture and 

Television Filming).

3.14 Operator will obtain an Air Traffic Organization (ATO) certificate of 

waiver or authorization (COA) prior to conduction UAS operations.

3.15 Operator, as required by the COA, will request a NOTAM be filed for the 

UAS operation at least 48 hours in advance, but not more than 72 hours in 

advance.

4. Conclusion

We feel confidant that with the above provided information the FAA can find 

Turbine Aircraft Logistics to qualify for the exemptions allowed under section 

333 of the FAA Modernization and Reform Act of 2012. We would be happy to 

answer any questions regarding this exemption request if needed.

 

Sincerely,

Carson W. Lee

President

Turbine Aircraft Logistics, LLC
Turbine Aircraft Logistics, LLC

5715 Oak Hollow Ln

Oviedo, FL 32765

386-385-8436

info@turbineaircraftlogistics.com

June 28, 2015 

U.S. Department of Transportation 

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Turbine Aircraft Logistics, LLC’s Submission of 

Requested Information for 333 Exemption 

FAA Regulatory Docket

FAA-2015-1150

NAME AND ADDRESS OF PETITIONER

Turbine Aircraft Logistics, LLC

Attn: Carson Wade Lee

5715 Oak Hollow Ln

Oviedo, FL 32765

386-386-8436

info@turbineaircraftlogistics.com
To!Whom!It!May!Concern:

This!letter!is!addressing!requested!information!requested!from!a!letter!dated!June!

24,!2015!for!a!section!333!exemption!to!be!granted!to!Turbine!Aircraft!Logistics,!

LLC,!Public!Docket!FAAK2015K1150.

The!following!reasons!were!cited!as!cause!for!the!exemption!request!to!not!be!

granted:

1. The!reasons!why!granting!the!request!would!be!in!the!public!interest;!that!is,!

how!it!would!benefit!the!public!as!a!whole.

2. The!reasons!why!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!you!seek!an!exemption

3. Any!additional!information,!views,!or!arguments!available!to!support!your!

request.

Please!treat!the!following!paragraphs!as!an!amendment!to!my!exemption request

dated!April!13,!2015.

Public'Best'Interest

Turbine!Aircraft!Logistics!believes!with exemption from!the!requested!regulations!it!

can!serve!the!public!best!interest!by!providing!photo!and!video!services!at!a!fraction!

of!the!cost!that!would!exist!preforming!the!same!services!in!manned!aircraft.!With!

aircraft!rental!cost!well!over!a!hundred!dollars!per!hour,!using!a!UAS!will!

accomplish!these!same!tasks!with!more!then!a!98%!reduction!is!operating!cost.!The!

public!will!befit from!this!reduction!in cost, as!the!end!consumer!will!be!charged!

considerably!less!for!a!better!quality!product.!Safety!is!the!top!goal!of!Turbine!

Aircraft!Logistics!and!the!pubic!as!a!whole.!We!believe!we!can!offer!services!in!a!

much!safer!manner to!the!public with!our!unmanned!aircraft!then!we!could!with!our!

manned!aircraft.!If!the!service!we!provide!was!accomplished!in!a!manned!

helicopter,!the!risk!of!flying!at!low!attitudes!inherently!increases!the!risk!to!the!

public!in!the!event!of!a!mechanical!difficulty.!The!UAS!has!very!few!moving!parts,!

greatly!decreasing!the!likelihood!of!a!mechanical!failure.!However,!even!in!the!event!

of!a!mechanical!problem!with!a!UAS,!the!likelihood!of!damage!or!injury!to!persons!

or!property!is!very!low!due!to!the!UAS’s!very!light!weight!(under!10lbs),!no!

flammable!fuels!carried!on!board,!and!plastic!propellers.!This!exemption!can!also!be!

found!in!public!interest!as!it!is!very!quite!comparatively!to!a!manned!aircraft,!low!

energy!usage,!and!zero!carbon!emissions.!

Equivalent'Safety'to'Regulations'Pertaining'to'Manned'Aviation'

Turbine!Aircraft!Logistics!is!uniquely!capable!of!providing!a!level!of!safety!at!least!

equal!to!that!provided!by!the!rule!from!which!we!seek!an!exemption.!Carson!Lee,!
the!chief!pilot!for!both!manned!and!UAS!operations!at!Turbine!Aircraft!Logistics,!has!

13!years!of!manned!aviation!experience!with!over!5000!hours!of!flight!time!accrued!

in!manned!aircraft!and!hundreds!of!hours!in!UAS!for!hobby!use.!Carson!also!holds!a!

FAA!issued!Airframe!&!Powerplant!mechanic!certificate!with!Inspection!

Authorization.!We!would!treat!our!UAS!just!as!we!do!our!manned!aircraft!with!

similar!inspection!practices!and!record!keeping.!Because!the!FAA!has!not!developed!

inspection!and!repair!methods!with!UAS,!we!will!follow!the!manufactures!

recommendation!for!inspection!intervals!and!repair!(see!Appendix!B!of!our!filed!

exemption!request).!UAS,!while!highly!technically!advanced,!are!very!simple!in!

design!with!very!few!moving!parts.!The!Inspire!1!UAS!has!4!rotors,!giving!it!

considerable!redundancy!as!it!can!continue!in!flight!with!a!loss!of!one!motor!as!the!

other!motors!adjust!in!speed!to!compensate. Our!UAS!is!capable!in!the!event!of!lost!

link!to!return!to!a!designated!safe!location!and!auto!land. We!are!highly!filmier!with!

FARs,!aeronautical!charts,!NOTAM!research!and!filing,!TFRs,!etc.! We!will!conduct!

preflight!planning!to!review!all!necessary!information,!including!but!not!limited!to:

reviewing!VFR!sectionals!to!insure!remaining!clear!of!

prohibited/restricted/MOAs/warning!areas;!airspace!other!then!class!G!(unless!a!

COA!has!been!granted).!Review!of!TFRs,!NOTAMs,!and!submitting!a!NOTAM!for!our!

proposed!flight!as!required.!Much!more!detail!on!our!safety!procedures!can!be!

found!in!section!III!of!our!exemption!request!dated!April!13,!2015.!

Additional'Information,'Views,'or'Arguments'to'Support'our'Request

Turbine!Aircraft!Logistics!views!our!long!experience!aviation,!working!closely!with!

the!local!FAA!FSDO!highly!qualifies!us!to!be!granted!exemption!from!the!requested!

FAR’s.!With!the!above!provided!information,!we!are!able!to!bring!a!far!higher!level!

of!safety!to!our!operations!that!few!section!333!exemption!holds!will!be!able!to!

offer.!With!our!manned!aircraft!relationship!with!the!FAA,!we!feel!confidant!we!will!

be!well!capable!of!adjusting!to!new!regulations!and!procedures!as!they!are!issued!by!

the!FAA.!

Please!contact!us!if!additional!information!is!needed.!

Sincerely,

Carson!W.!Lee

President

Turbine!Aircraft!Logistics,!LLC