Petition of Exemption 

For Tango Whiskey Concepts LLC

Timothy A Worthy

1212 Knoll Ridge Dr

Cedar Park, Texas 78613

907-687-9578

Request exemption from:

14 CFR Part 21

14 CFR Part 23

14 CFR Part 43

14 CFR Part 45.23(b)

14 CFR Part 61.113(a) and (b)

14 CFR Part 91.7(a)

14 CFR Part 91.9(b)

14 CFR Part 91.103

14 CFR Part 91.109

14 CFR Part 91.119(c)

14 CFR Part 91.121

14 CFR Part 91.151(a)

14 CFR Part 91.203(a) and (b)

14 CFR Part 91.205(b)

14 CFR Part 91.405(a)

14 CFR Part 91.407(a)(1)

14 CFR Part 91.409(a)(1) and (2)

14 CFR Part 417(a) and (b)

This exemption would allow Tango Whiskey Concepts LLC to operate the Phantom 3 Vision 

Quad Copter unmanned aircraft system (UAS) to conduct aerial videography and photography 

in the United States Airspace Structure.

The owner of Tango Whiskey Concepts LLC, Timothy A. Worthy, seeks to build on his 12 plus 

years of successful and safe aviation operations and leverage his aviation skills and knowledge 

to offer the widest possible range of UAS services in a manner that is consistent with the intent 

of Congress in enacting Section 333. Tango Whiskey Concepts LLC seeks the requested 

exemptions and a Certificate of Authorization to permit Tango Whiskey Concepts LLC to offer 

on-demand commercial UAS operations for multiple commercial and industrial applications 

including: 

• Aerial surveying 

• Agriculture inspection and mapping

• Aerial photography and filmmaking

• Public entity support operations 

• Utility system inspections 

• Structural inspection and monitoring

• Wildlife surveys 
• Forestry monitoring 

• Educational and research operations 

• Pipeline inspection and patrolling

• Law Enforcement investigations

• Search and Rescue

• Disaster surveys

• Insurance investigations

• Real Estate

• Overwater 

14 CFR Part 21 Airworthiness Certificates

I request the UAS not be either a certificated aircraft or a certificated “experimental” aircraft. 

Exemption from display of markings is requested due to size and airspace that is will operate in.

CFR 45.23(b) Display of marks; general

I request the UAS not to be either a certificated aircraft or a certificated "experimental"

aircraft. Exemption from display of marks is requested due to its size and airspace that it

will operate in.

CFR 61.113(a) and (b) Private pilot privileges and limitations: Pilot in command

As I, Timothy A. Worthy, currently hold a Commercial Helicopter Instrument certificate with a 

second-class airmen medical certificate and am currently a UH-60L pilot in command for the US 

Army Reserve with over 1900 accident free hours, I understand the importance to be knowledgeable 

of the National Airspace System (NAS). However, I request that a non certificated pilot be able to 

operate the UAS with direct and written discretion of a certificated pilot with proper ground, 

operation and airspace training that is established by that certificated pilot. This appointed pilot 

would be tested in aircraft operation, maintenance, emergency procedures and the NAS before 

assuming operation of the UAS. A proper training program will be in place with documentation and 

training logs.

CFR 91.7(a) Civil aircraft airworthiness

Given that the UAS will not require an airworthiness certificate in accordance with 14 CFR part 21, I 

request exemption. Also, there is no FAA regulatory standard for determining the airworthiness of an 

UAS. The manufacturers operating documents will be used by the operator to determine if the UAS 

is airworthy.

CFR 91.9(b )(2) Civil aircraft flight manual, marking, and placard requirements

Followed by exemption from CFR 45.23(b). Manufacturers operating manual shall be used and kept 

by the operator on location of UAS operations.

CFR 91.103(b) Preflight action

While there is no approved airplane or rotorcraft flight manual available for the UAS the 

manufacturers operating manual is requested to be used for proper preflight. Runways and airports 

will not be used to deploy or recover the UAS excluding them from the preflight/planning action.
CFR 91.109 Flight introduction; simulated instrument and certain flight tests

Although the UAS does not allow operation with a dual set of controls, proper hands on training of 

UAS operation will be given to any operational pilot by a certificated pilot who has sufficient UAS 

operation hours. Simulated training may be used for sufficient operational training. All pilots will be 

familiar with preflight actions, routine flight operations, and emergency procedures.

CFR 91.119 Minimum safe altitudes: general

Line of Sight operations will allow flight below minimum safe altitudes. The minimum safe altitude 

was initially established for manned aircraft. Keeping UAS below the minimum safe altitude will 

allow for better airspace deconfliction with manned aircraft.

CFR 91.121 Altimeter settings

As the UAS does not have an adjustable barometric altimeter an exemption is required. An 

equivalent level of safety will be achieved by the PIC, confirming the altitude of the launch site via 

the UAS GPS.

CFR 91.151(a) Fuel requirements for flight in VFR conditions

The UAS shows a low voltage warning when 30% battery life is remaining. This provides ample 

time for the UAS operator to land in an safe area. Also, the UAS is equipped with an automated 

function that lands the aircraft immediately when a critical battery is detected.

CFR 91.203(a) and (b) Civil aircraft: certification required

Operations of the UAS prove to be above safety standards due to its size, weight, speed, and limited 

operating area that it will be operated in and it does not carry a crew or passengers.

CFR 91.405(a) Maintenance required

This only applies to aircraft with airworthiness certificates. Maintenance of the UAS will be 

performed by the operator if a discrepancy is found during pre-flight and recorded on a "Maintenance 

Log" for personal history records.

CFR 91.407(a)(l) Operation after maintenance, preventive maintenance, rebuilding, or 

alteration

This only applies to aircraft with airworthiness certificates. Maintenance test flights will be 

performed after each maintenance discrepancy is corrected as a safety precaution and recorded on a 

"Maintenance Test Flight Log" for personal history records.

CFR 91.409(a)(l) and (2) Inspections

This only applies to aircraft with airworthiness certificates. Pre-flight will be performed as a safety 

precaution by the operator using the outlined procedures in the operating documents.

CFR 91.417(a) and (b) Maintenance records

This only applies to aircraft with airworthiness certificates. Any maintenance performed on the UAS 

will be recorded on a "Maintenance Log" for personal history records

Tango Whiskey Concepts LLC requests exemption from the 14 CFR Part 21, 14 CFR Part 23, 14 

CFR Part 43, 14 CFR Part 45.23(b), 14 CFR Part 61.113(a) and (b), 14 CFR Part 91.7(a), 14 CFR 
Part 91.9(b), 14 CFR Part 91.103, 14 CFR Part 91.109, 14 CFR Part 91.119(c), 14 CFR Part 91.121, 

14 CFR Part 91.151(a), 14 CFR Part 91.203(a) and (b), 14 CFR Part 91.205(b), 14 CFR Part 

91.405(a), 14 CFR Part 91.407(a)(1), 14 CFR Part 91.409(a)(1) and (2), 14 CFR Part 417(a) and (b) 

regulations in order to commercially operate unmanned aircraft systems in the National Airspace 

System to support a variety of industrial and commercial applications, to include, but not limited to: 

Aerial surveying, Agriculture inspection and mapping, Aerial photography and filmmaking, Public 

entity support operations, Utility system inspections, Structural inspection and monitoring, Wildlife 

surveys, Forestry monitoring, Educational and research operations, Pipeline inspection and 

patrolling, Law Enforcement investigations, Search and Rescue, Disaster surveys, Emergency 

Operations Support, Insurance investigations, Real Estate, and Overwater operations. Granting 

Tango Whiskey Concepts LLC’s request for exemption will reduce current risk levels and thereby 

enhance safety. UAS operations would provide a safer, more efficient way of operating aviation 

assets to potential individuals and companies looking for new and improved ways of utilizing 

aviation assets within the State of Texas and promote economic growth overall. Also, the aerial 

photography and videography would allow small business owners a more feasible option for 

marketing and advertisement over the high cost of manned rotary/fixed wing aircraft as in the past. 

Further, the UAS operation increases the safety of patrons due to its small size and lack of 

combustible fuel compared to a large manned aircraft and reduces the ambient noise level helping to 

prevent noise complaints. The UAS proves to be more ecological by emitting no exhaust fumes and 

requires no fossil fuels for operations. UAS operations allow access to areas during natural disasters 

and aid in search and rescue efforts, allowing other manned aircraft to continue more critical 

missions. 

Granting UAS operations will help reduce aviation traffic and allow UAS to operate in close 

proximity to buildings and objects that conventional aircraft cannot approach. And allow an 

economical alternative to a bird’s eye view for a multitude of operations.

Timothy A. Worthy

Tango Whiskey Concepts LLC

August 23rd, 2015