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 letter s 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 ai rcraft system (UAS) to conduct aerial photography and videography

.

See Appendix A for the petition submitted to the FAA des cr ibing 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 pr ecedent, 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, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in2

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

, C ertification procedures fo r 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 collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 20 14

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , 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 peti tioner 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 i nterest.

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 g ranted 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 (part iculate measurement, etc.), or any other gathering of data by

instruments aboard the UA.3

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 Inspir e 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 p ermitted.

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 b e 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

cap ability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic 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

duratio n 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

ex emption, are hereinafter referred to as the operating documents. The operating

documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and

limitations in this exemption and the procedures outlined in the operating documents,4

the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may upd ate 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 rev ised 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 FA A’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 fl ight 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 condit ion 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 Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.5

14. The o perator 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 (traini ng, 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 co nducted during dedicated training sessions. During

traini ng, 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 nonpa rticipants 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 symbo l as denoted on t he 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 commun ications or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate 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 cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations tha t cannot be conducted under the terms of the attached COA

.6

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear a nd 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, v ehicles, 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 protectio n. 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 t rainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or authorized representative.

P ermission 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 FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions

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

.7

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the a rea 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 th e 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 invol ved 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 operati on.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption , the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to,

parts 45, 47, 61, and 91.8

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

Sincerely,

/ s/

John S. Duncan Director, Flight Standards Service

Enclosures1

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.com2

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

Pub. L. No. 112

- 95 (2012), 126 Stat. 11 (“Sect ion 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

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

• Reliability

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

• Return to designated point automatically with a low battery that is dynamically updated depend ing 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 air craft airworthiness)

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

• FAR 91.103(b)(1) ( Preflight action)3

• 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 seek s 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 6.47 lb 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 “ R eturn T o
H ome ” (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

contro l of the UAS. In the event of lost GPS signal, control to the Ins pire 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 re gister the UAS IAW FAR part 47. The operator’s UAS

will have identification m akings 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 ba rometric altimeter system. The

I nspire 1 UAS collects altitude informati on for t wo sources: GPS and

barometric a iding . 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 A GL for the duration of the flight.4

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 d etermined that it c an operate

t he 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

- f light 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 followi ng paragraph.

B ecause 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 r equesting 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

recom mended 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 buil ding 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 fo r 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.

Carso n has accrued 12 hours as PIC wi th 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:5

• Hold a FAA Private Pilot

• Hold a FAA third class m edical 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 mi nimum 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 responsi bility 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 condu cted 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 fl ight 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 tow er 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 fr om 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 s et 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 oper ations.

3.15 Operator, as required by the COA, will request a NOTAM be filed for the UAS operation at least 48 ho urs 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

Tur bine 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, LLCTurbine 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: Ca rson Wade Lee

5715 Oak Hollow Ln

Oviedo, FL 32765

386

- 386

- 8436 info@turbineaircraftlogistics.comTo!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!gra nted!to!Turbine!Aircraft!Logistics,! LLC,!Public!Docket!FAA

K 2015

K 1150.

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!th e!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!arg uments!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!s erve!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!thes e!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!t he!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!attit udes!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!likel ihood!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!comparativel y!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!ru le!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!hour s!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,!NOT AM!re search!and!filing,!TFRs,!etc.! We!will!conduct! preflight!planning!to!review!all!necessary!informatio n,!including!but!not!limited!to: reviewing!VFR!sectionals!to!insure!remaining!clear!of! prohibited/restricted/MOAs/warning!areas;!airspace!other!then!cl ass!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'I nformation,'Views,'or'A rguments' 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!inf ormation,!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!regu lations!and!procedure s!as!they!are!issued!by!

the!FAA

.!

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

Sincerely

,

Carson!W.!Lee

President Turbine!Aircraft!Logistics,!LLC