**U.S. Department of Transportation**

**Docket Management System 1200 New Jersey Avenue, SE**  **Washington, D.C. 20590 February 12, 2015** 

**Westec Tower Services , Inc.**  **Jacob Davis / President**

**RE: Exemption Request Section 333** of the **FAA Reform Act of the Federal Aviation Regulations**  from 14 CFR 91.7(a); 91.9(B)(2);91.119 (c); 91.121; 91.151(a)(1); 91.203(a)(b); 91.405(a); 91.407(a)(1); 91.409(a)(1)and (2); 91.417(a)&(b); 45.23(b); Part 21 ; 61.113(a)(b)

Dear Sir or Madam: We are writing purs uant to the FAA Modernization and Reform Act of 2012 ( Reform Act), and the procedures contained in 14 C.F.R. 11, to request that WesTec Tower Services, Inc

. , A Telecom General contractor an owner and operator of small unmanned aircraft, be exempted from t he Federal Aviation Regulations (FARs) listed above so that WesTec Tower Services may operate its small unmanned aircraft / lightweight unmanned aircraft system (UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA); as long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.
WesTec Tower Services formally known as IWS / WCCS Inc. was founded in 1989 to provide heavy civil and full s ervice general contracting services to the telecommunication industry WesTec is a full service Telecom General Contractor/ Federal Government vendor which provides services to the telecommunication, Heavy civil, and federal construction industries. Westec provides structural and civil Engineering / Program and Project Management / Structural tower mods/ Structural Tower erection / Tower structural and civil augmentations / Tower Retrofitting /Tower Foundation Engineering / Tower Foundation construction / Electric / Telco service / New site build / New Microwave system construction / Radio integration / Structural inspections and maintenance.WesTec Tower Services employs a group of experienced UAS Operators / Pilot s. These pilots

have all been train ed and received operator certifications from multi

- rotor manufacturers on several different platforms including the ones listed here

- in. They are also FAA licensed light sport, private & commercial pilots. The chief pilot / instructor / program manager has operated multi

- rotor aircraft for several years as a hobbyist wit h over 500 hours PIC. He has spent many years operating several different unmanned systems stateside & overseas for the U.S. Military. This includes fixed wing and rotor

- craft platforms. He has tr ained Army personnel to use UASs in combat operations . He has been trained on all aspects of a UAS

- piloting ( internal & external ), CRM, payloads, maintenance & repair, trouble shoot computer systems & auto

- pilot software, flight planning & b riefings, radio link communications and frequency de

- conflicting, ATC communications (operations with airspace controllers and towers). He is a licensed FAA Commercial Pilot with an Instrument Rating with over 600 hours PIC. He retains a Class II Medical Certificate. It is the request of the petitioner for exemptions listed above in order to legally and safely operate the **DJI Phantom 2 Vision + , DJI S** 
**- 900**  **/ S** 
**- 1000**  **and the DJI Inspire UAS**  in the National Airspace System, for the purpose of Unmanned Aeria l Photography , Inspection and Videography for the utility, telecommunications and petro chemical industries . In order to perform these duties effectively we request operational altitude of 400 ft AGL and below . Enhancement of Public awareness of UAS oper ation and finally enhanced safety for both the General Public, Flight Crews and the Labor Force described herein. The main purpose for the requested Exemption is to allow WesTec Tower Services to utilize its UASs to inspect cellular, radio and broadcast towers for telecommunications Carriers, Tower operator company’s, broadcast company’s and there vendors

. WesTec Tower Services has been given consent to access these secure sites. The site access allows WesTec Tower Services to perform all inspections at l ow altitude and always within VLOS. All flight operations will be with a 25 ft radius around the cell tower, so the flight plan foot print is very small. Operations will remain below 400 ft AGL

. WesTec Tower Services will cordon off the site to keep the p ublic safe. Not only would public safety be of utmost concern but also the safety of the climbing crews tasked with routine inspection of the towers. WesTec Tower Services and its UASs would alleviate the day to day height exposure and potential risk for an accident while preforming the vertical inspection portion. This will allow them t o concentrate on service and maintenance. Telcom Structural Climbers have one of the highest incidents of death in the labor force. Thi s is why we seek this exemption to help provide a alternative method for tower inspection. We are confident that if we are allowed to implement the use of our UAS program it will save lives. The secondary request for Exemption is to allow WesTec Tower Services to utilize its UASs to insp ect power transmission lines for the utility companies and their subcontractors. This would reduce the need for low flying manned helicopters. These manned flight systems have a relatively good safety record. The use of UASs would reduce the carbon foot pr int and noise pollution. Limiting and/or reducing these manned operations would also reduce exposure to the public and power grid infrastructure in general. The operations that WesTec Tower Services would perform would be localized, remain VLOS, under 400 ft AGL , utilize a PIC & VO. The third request for Exemption is to allow WesTec Tower Services to utilize its UASs to assist industrial petro / chemical plants to inspect the conditions of their infrastructure. WesTec Tower Services has for many years be en involved with construction and inspection of tower / ve rtical infrastructure at these plants. These areas are controlled by the plant owners and limit access to plant employees and prohibi t access to the general public. Access to these areas is only gra nted with supervision by plant management / safety inspectors. WesTec Tower Services currently inspects andmaintains vertical structure using manned crews. UASs are to be implemented as part of their current

operations. This would enable the inspection di vision to quickly and safely perform day to day operations without shutting down plant processes. The use of UASs would create a safer environment for the climbers and plant employees on the ground. The operations that WesTec Tower Services would perform would be localized, remain VLOS, under 4 00 ft AGL, utilize a PIC & VO.
WesTec Tower Services exemption request would permit its operation of lightweight, unmanned (remotely controlled in line of sight) UAS in tightly controlled and limited airspace. Predetermined, specifically marked areas of operation, cordoned off locations and corresponding enhancements to operate within current safety parameters and new ones being implemented. It is the petitioners positi on that the operations for which exemption is requested are safer and more cost effective than using manned aircraft, and for those reasons are in the Public Interest; and would be of benefit in identifying areas of operation that may need additional overs ight as well as raising public awareness and interest in this rapidly growing facet of aviation.

The petitioner will outline in this document:
**1. Request for exemptions by Part and Subpart**  **2. Petitioners protocols and procedures for operations**  **3. Request**  **for relief from Airport Proximity Limitation 4.**  **The Unmanned Aircraft System (UAS) 5.**  **The Public Interest**

# 1. **REQUESTS FOR EXEMPTION BY PART AND**

**SUBPART**

**14 CFR 91.7(A)** Airworthiness Certificate; Prohibits the operation of an aircraft without an airworthiness certificate. Petitioner requests exemption based on previous **Exemption No. 11138** . The FAA has ruled that this make and model of aircraft (UAS) does not require an airworthiness certificate

.

**14 CFR 91.9 (B) (2)** Aircraft Flight Manual in the aircraft; Requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS, this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual at the flight operations center. The FAA has previously issued exemptions to this regulation in **Exemption No. 10700 and 32827**

**14 CFR 91.119(C)** Minimum Safe Altitudes; States that no person may operate an aircraft below th e following altitudes: over other than congested areas, an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. The petitioner will never opera te any UAS over an altitude of 400 AGL. The majority of the operation s proposed will operate around 200 to 300 f t AGL as this usually provides the best angle of capture for the type of photography and videography operations proposed. The UAS utilized for this exemption is of exceptio nally light weight and is not capable of speeds over 30 knots. The UAS is equipped with GPS guided auto pilot with a return home function in case loss of control by the PIC and is powered by sealed batteries thereby reducing the chance of post impact fire to nearly zero. There will be cases when the 500 foot distance from structures will need to be exempted. (Example: Aerial Video of a 2 story home roof to determine and/or document extent of storm damage.) In this type of operation every assurance will be made to keep persons outside of areasonable, safe, clear area of operations and will only be conducted with the express permission of

the property owner. See **Protocols and Procedures Section**

. The petitioner will implement procedures and policies t o ensure that any person in the general vicinity of operations will be aware of such operations and ensure that all non

- essential personnel are cleared of the area of operations. See **Protocols and procedures Section 3.** The petitioner therefore requests re lief in part from **14 CFR 91.119(C)**

**14 CFR 91.121** Altimeter Settings; The petitioner requests relief from **91.121** for the following reason. The UAS is equipped with GPS derived altitude capability, however due to the limited altitude requested in this exe mption, the FAA has previously granted Exemption for these types of operations. **Reference Exemption No. 11138** 

**14 CFR 91.151(a)** Fuel for Flight; No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weathe r conditions) unless there is enough fuel to fly to the first point of intended landing and, assuming normal cruise speeds (a)(1)During the day to fly for at least 30 minutes. The petitioner requests relief from **91.151(a)** due to the fact that the UAS is equipped with a battery and percentage indicator system. The UAS has a flight capability on full charge of approximately 20 to 25 minutes depending on camera usage and other variables. The petitioner has established that the maximum flight will be 10 min utes on a fully charged battery. This constitutes landing with approximately 50 percent fuel remaining. The petitioner believes that this follows the spirit and intent of the rule with a great margin of safety. No UAS operations will be conducted at n ight, as defined by Federal Aviation Regulations.

**14 CFR 91.203(a)(b )**  Carrying of civil aircraft Certifications and Registrations; Provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining such certifications and registrations at the UAV Field Services flight operations center.**14 CFR 91.405(a)**

Maintenance required; The petitioner requests relief in part from **91.405(a)(1)** based on the **Protocols and Procedures Section**  on **Maintenance and M aintenance R**  **ecords**

. **Also reference Exemption No. 11138**

**14 CFR 91.407(a)(1)**
O peration after maintenance, preventive mainten ance, rebuilding, or alteration; The petitioner requests relief from **91.407(a)(1)** based on the **Protocols and Procedures Section** on **Maintenance, Return to service after maintenance, and Maintenance records**  **. Reference Exemption No. 11138** 

**14 CFR 91.409(a)(1)(2)** Inspections; The petitioner requests relief from **91.409(a)(1)(2)** based on the **Protocols and Procedures Section**  on **Inspections. Reference Exemption No. 11138** 

**14 CFR 91.417(a)(b)** Maintenance records; The petitioner requests relief from **91.417(a)(b)** based on the **Protocols and Procedures Section** on **Maintenance records**

.

**14 CFR 45.23(b)** Marking of the Aircraft; Applicable codes of Federal Regulation require aircraft to be marked acc ording to certain specifications. WesTec Tower Services UASs are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two inch lettering is difficult to place on such sm all aircraft. Regardless, WesTec Tower Services will mark its UASs in the largest possible lettering by placing the word "EXPERIMENTAL" on its fuselage as required by 14 CFR 45.29 (f) so that the pilot, technician, spotter and others working with the UAV w ill see the markings. The FAA has previously issued exemptions to this regulation through **Exemption No 10167 and 10700 14 CFR 21, Sub Part H** 

Airworthiness Certificates; Entitled Airworthiness Certificates, set forth requirements for procurement of neces sary airworthiness certificates in relation to FAR 91.203(a)(1). The size, weight and enclosed operational area of WesTec Tower Services UASs permits exemption from Part 21 because WesTec Tower Services UASs meet an equivalent level of safety pursuant to S ection 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 USC 44701(f)) and Section 333 of the Reform Act. Both pieces of the legislation permit the FAA to exempt UASs from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. WesTec Tower Services UASs meet or exceed each of the elements.

**14 CFR 61.113 (a)(b)**  Private Pilot Privileges and Limitations / PIC; Private pilots are limited to non

- commercial operations. WesTec Tower Services can achieve an equivalent level of safety as achieved by current Regulations because UAV Field Services UASs do not carry any pi lots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills, though UAV Field Services pilot vetting and training program will. Further, private pilot licensees will operate WesTec Tower Services UASs with the same skill. Further, the risk attendant to the operation of WesTec Tower Services UASs is far less than the risk levels inherent in the commercial activities outlined in CFR 61. Thus, allowing WesTec Tower Services to operate its UASs with a private pilot as the pilot in control will exceed current safety levels in relation to CFR 61.113(a)(b).

# WesTec Tower **Services**

**2. Protocols and Procedures for UAS operations.** 

**A. Preflight**  **B. Area Security**  **C. Limitations of Operations**  **D. Airworthiness**  **E. Maintenance and**  **Records F.**  **Pilot in Command Requirements G.**  **Visual Observer and Requirements H.**  **Reporting of Incidents and Accidents**



## A. **Preflight Inspection of UAS (1).**  Preflight of the Unmanned Aerial System will follow the instructions in the DJI instruction and User Manual

. The Pilot in Command will certify that a preflight inspection has been accomplished with the date and time and signature in the UAS logbook. The preflight shall include the aircraft, transmitter, and batteries, motors, rotors, landing gear, camera and gim bal mount. As a part of the preflight the Pilot in Command will assure that weather conditions , area security, and any other information essential to safe operation has been obtained.



## B. **Area Security**
**(1).** The PIC of the UAS will ensure that the operation al area for the purposes of UAS flight shall be cleared of all nonessential persons at all times the UAS is in flight. Additionally all nonessential persons shall be required to remain clear of the operations area by a minimum distance of 150 feet during operations. PIC shall ensure that clearly marked signs are posted at all ingress\egress points to the operations areas. These signs will be of white background with red lettering stating the following: “Unmanned aircraft operations underway. Please rema in clear.” **(2).** In the event of a breach by nonessential persons into the operations area during the flight of UAS, the PIC shall immediately terminate flight operations until such time as the area can be cleared of these persons. **(3).** The UAS area of operation is defined as the Horizontal flight path(s) of the UAS as well as the Vertical flight path and Maximum altitude to be reached. Additionally the areabetween the UAS’s current position and its Home location is also considered operational area as it will proceed direct to its home location in the event of loss of ground control. **All nonessential persons will not be allowed within 150 feet of any part of the operational area during flight operations.** 



## C. **Limitations of Operations**
**(1)** The UAS shall be operated in Day time only, as defined by **14 CFR (2)**  UAS night operations are prohibited. **(3)** The UAS shall be operated by VLOS at all times **(4)** A Visual Observer shall be utilized at all times and must maintain VLOS at all times. **(5)** The UAS shall remain within 1000ft horizontal distance of the PIC at all times. **(6)** The UAS to be utilized is the **DJI Phantom 2 Vision + Unmanned Aircraft System** . No other systems will be operated. **(7)** The UAS will h ave an altitude restriction of 400ft AGL. **(8)** The UAS will not be operat ed at a speed exceeding 30 Knots. **(9)** Operations Documents will be accessible to the PIC at all times and must be accessible during UAS operations and made available to the Administrator on request. **(10)** PIC must inspect and ensure that UAS and ground control stati on is in airworthy condition prior to each operation; if determined un

- airworthy, all operations will be suspended until such time as necessary maintenance has been performed and the UAS is determined to be in a safe condition for flight. **(11)** An operational fl ight test is required after any maintenance or alterations that may affect UAS operation or flight. **(12)** UAS maintenance must follow Manufactures aircraft/component, maintenance, overhaul, and replacement, inspection, and life limit requirements. **(13)** The operator m ust carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance and inspection, and alterations must be noted in the aircraft records, including total flight hours, description of work p erformed, and the signature of the authorized person returning the UAS to service. **(14)** UAS must comply with all Manufacturers’ Safety Bulletins. **(15)** An authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. **(16)** UAS must by operated by a PIC possessing at least a Private Pilot Certificate, with most appropriate Class and Category and at least a current Third Class Medical. **(17)** PIC must meet the flight review requirements of 14 CFR 61.5 6 in an aircraft in which the PIC is rated. **(18)** Prior to operations for which exemption is requested the PIC must have accumulated and logged , in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours of UAS multi

- rotor. **(19)** Prior to operations PIC must have accumulated and logged a minimum of 5 hours as a UAS pilot in make and model listed in exemption. PIC must log at a minimum 3 takeoffs and landings in the preceding 90 days to meet currency requirements. **(20)** PIC is required to operate the UAS in accordance with 14 CFR 91.119.**(21)** No Private Pilot may operate UAS within 5 nautical miles of an airport reference point as denoted on a current FAA chart. **(22)** Operations with 5 NM of an airport must b e conducted by a PIC who holds at least a Commercial Pilot Certificate and a current Second Class Medical. **(23)** No operations are allowed in the surface areas of Class B, C, and D airspace. **(24)** No operations are allowed if the return home function and \or autopilot are, or are suspected to be malfunctioning. **(25)** UAS shall not be operated from a moving platform of any type. **(26)** No operations shall be conducted without an appropriate Certificate of Authority issued by the Administrator. **(27)** A Visual Observer shall be utilized at a ll times when operating the UAS. **(28)** Should the PIC or Visual Observer detect that a manned aircraft is being operated in close proximity to the operations area, the UAS shall give right of way to the manned aircraft, and the PIC shall cease operations and lan d until such time as the manned aircraft has cleared the area. **(29)** The UAS will not be operated any closer than 500 feet to any structure without the express permission of the structure owner.



## D. **UAS Airworthiness (1)**  The PIC shall ensure that the UAS is in an airworthy condition before each flight. Airworthiness shall be determined by a preflight inspection in accordance with DJI operating documents and any and all applicable Federal Aviation Regulations, and any additional requirements as defined by the Admi nistrator. PIC shall document each preflight inspection by date, Aircraft total Flight time to date, any discrepancies noted, and signature and certificate number. Any discrepancy noted shall be addressed before UAS operation.



## E. **UAS Maintenance and Recor ds** 
**(1).** the operator shall maintain aircraft maintenance logbooks. Each UAS shall have its own and separate maintenance log book. DJI documents, handbooks, user manuals, supplements, Safety Bulletins, etc., shall be the only approved documents for perfo rming repairs, maintenance, inspections, overhauls, or replacement of life limited components. A record of each preflight inspection will additionally be recorded in these logbooks. The preflight inspection must be conducted by the PIC for that operation. Preflight signoff shall include at least the following information: date of operation, Aircraft Total time, aircraft serial or operating number, PIC signature and certificate number. **Example:** Preflight inspection completed, No defects noted. 1

- 1

- 15, ACFTT 50.1 hours, UAS number 1, Name

- PIC **(2).** Any required maintenance, inspection, alteration or repair must be completed by an approved person. At the completion of this work the approved person must make an entryin the aircraft log book that at l east includes: Date, Aircraft serial or operating number, brief description of the discrepancy, inspection, alteration or repair, the reference material used as guidance for the repair, statement approving the aircraft for return to service, and signature of person who completed the work. Example: 1

- 1

- 15 UAS 1, ACFTT 50.1 hours, replaced number 3 rotor with new rotor, IAW DJI Phantom 2 Vision + User Manual. Flight or ops check completed. Aircraft is approved for r eturn to service. **(3).** Maintenance records shall be kept with the UAS at all times and shall be made available to any authorized agency or the Administrator upon request.



## F. **Pilot in Command Requirements**
**(1).** The Pilot in Command shall hold at least a Private Pilot Certificate and a current Third Class Medical whenever conducting operations. Operator prefers that the Certific ate be in the most appropriate Class and C ategory to the UAS being operated. **(2).** Th e Pilot in Command shall have at least 25 hours of rotorcraft UAV flight time before performing any operation for which exemption is requested. **(3).** The Pilot in Command shall have at least 5 hours in make and model before performing any operation for whic h exemption has been requested. **(4).** The Pilot in Command shall perform a pre

-flight inspection before each flight is conducted. **(5).** The Pilot in Command shall observe all Federal Aviation Regulations at all times with the exceptions of the exemptions reque sted by the operator. In those cases the Pilot in Command shall adhere to company operating standards or Federal Aviation Admin i stration Limitations placed upon exemptions, whichever is more stringent. **(6).** The Pilot in Command must hold a Commercial Pilo t Certificate and a current Second Class Medical to operate within 5 NM of an airport. **(7).** The Pilot in Command will not operate the UAS without a Visual Observer present. **(8).** The Pilot in Command must have 3 takeoff and landings within the preceding 90 days. **(9).** The Pilot in Command must maintain a record of flight information to establish currency and that he or she meets the requirements of this section.



## G. **Visual Observers: Responsibilities and Requirements**
(1). A Visual Observer shall be used duri ng any and all operations of the UAS System. (2) . The Visual Observer shall maintain communication with the PIC at all times during UAS operation.(3). The Visual Observer shall maintain Visual Contact with the UAS at all times. In the event th at Visual Contact is lost the VO will notify the PIC who will immediately cease operations and land the aircraft. (4). The Visual Observer shall also help the PIC maintain area of operations security and ensure that all nonessential persons remain clear of the area of operations. In the event of a breach by unauthorized person(s) the VO shall notify the PIC and operations will cease immediately. (5). The Visual Observer shall also assist the PIC in looking for manned aircraft traffic near the operation s area. If manned aircraft traffic is observed near the operations area, the VO will notify the PIC who will immediately cease operations and land the UAS.



## H. **Reporting of Incidents and/or Accidents** Any incident or accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported within 24 hours to: FAA UAS Integration Office (AFS

- 80) Accidents: National Transportation Safety Board

www .ntsb.gov.



# 3 **. Request for Relief from Airport Proximity Limitation**

The petitioner understands the FAA’s concern for placing restrictions on the proximity a UAS can be operated in relation to an airport. However, the petitioner believes that certain relief can be granted in this matter based on the circumstances of the flight, altitude of the flight, and the area of the flight in relation to traffic patterns and protected instrument approach corridors. Also , the size and traffic of the airport certainl y should be considered as a factor . The petitioner believes that pilot qualifications, ratings, and aeronautic experi ence; as well as communication with the airport, any ATC controlling facility, and aircraft in the area would fully mitigate any dangers . The petitioner also believes that since many rural airports often host model and remote c ontrolled aircraft clubs and events without affecting normal operations, that measures could be put in place to ensure the safety of operation and integrati on of UASs’ in close proximity to certain airports. From a commercial standpoint a great deal of potential opportunity is lost when an area of close to 78.5 square miles is off limits. As UAS operations become more prominent consumers will demand these s ervices closer to airport facilities. It would not be in the interest of aviation or the public in general, to restrict these consumers from products or services because of their proximity to an airport. Thiscould cause a negative impact to both the consu mer and the airport. The petitioner therefore

proposes the following reasonable restrictions that would ensure that the majority of these consumers could be serviced and the safety of operation of manned aircraft could be assured. As previously stated most operations in the Scope of this requested Exemption will be conducted at or below 400 ft AGL. Any manned aircraft operating in the vicinity of an airport should not be at these altitudes over persons or property unless they are in the process of a take

- off or landing. Additionally they should be well aligned with either the approach or departure runway at these altitudes. The petitioner therefore requests relief in part from the 5 NM limitation concerning proximity to an airport based on the following restrictions. Note: Class B, C, and D airports not included in this relief request. Airspace must be E or G for relief to be requested.
**1.** Altitude restriction of 150 feet AGL within 3 to 5 Nautical miles of an airport.
**2.** Altitude restriction of 100 feet AGL within 1 to 3 Nautical miles of an airport.
**3.** No flight on the extended centerline s or 5 degrees to either side of any active or used runway out to 2 Nautical miles from Airport reference point.
**4.** Notify airport of proposed time, distance and he ading from airport of UAS operation.
**5.** Request issuance of NOTAM specifying UAS operations.
**6.** No flight within 1 NM of airport. This would mitigate the possibly of operating near the airport t raffic patterns.
**7.** The PIC shall make “ in the blind ” broadcast s of UAS operations on the appropriate frequency stating. “Unmanned Aircraft Operations underway. Distance and bearing from airport and operating altitude”

. **8.** The Pilot in Command of the UAS must be a Certificated Commercial Pilot with Class and Category Rating mo st appropriate to the UAS for which the Exemption is granted. In this case. Commercial Pilot Instrument Rated with a current Second Class Medical.
**9.** Anytime the PIC or Visual Observer has visual contact with a manned aircra ft, or anytime an aircraft requests, operations will be immediately suspended and UAS will descend and land immediately.
**10.** Aircraft has onboard programmable altitude restriction capability to help mitigate the possibility of inadvertent altitude devia tion. This function must be used during operations within 5 nautical miles of an airport.
**11.** The dorsal (top) area of the aircraft will be painted a bright safety orange to increase visibility of the aircraft from manned aircraft.

The petitioner believes that these restrictions and requirements safely mitigate the potential hazards associated with operation s near small, low volume airport s . In fact, the petitioner believes that this limitation would make this operation safer than many others that are conducted at thesetypes of airports ; to include : aerobatics training, parachute operations, and Amateur Radio

Controlled Aircraft Club s that are frequently located on these types of airports. The altitude restrictions requested would eliminate the p ossibility of a collision with manned aircraft as there is no reasonable circumstance where a manned aircraft should be at or near these altitudes, unless being on short final for approach or on departure

. In fact the petitioner believes that any manned aircraft operating at, or near these altitude restrictions , other than on short final for approach or on departure, would be operating in a careless and reckless manner. Petitioner also believes that requiring that the PIC hold a Commercial Pilot C ertific ate of most appropriate Class and C ategory helps to ensure that the operator has the knowledge, aeronautical experience, radio communication skills, and ability to safely operate within close proximity to airports located in class E and G airspace.
Petitio ner also believes that in the highly unlikely event of a collision between a UAS and a manned aircraft that the damage possibility, is no more than that of a small sized bird strike due to the extremely light weight and size of the UAS. However, the petit ioner should like to reiterate that the restrictions requested in this relief would make such a collision improbable , if not nearly impossible.



# 4. **The Unmanned Aircraft System UAS**
The petitioner will operate the DJI Phantom 2 Vision + , DJI S

- 900 / S

- 1000 and the DJI Inspire 1 UAS System s . The petitio ner has attached the operating and user documents for the system as additional supplements for this petition in the comments area . No modification to the factory system is to be utilized other than the dorsal surface area of the aircraft will be painted a bright safety orange to help manned aircraft see the unit while in flight. Please see attached supplemental documents.



# 5. The Public Interest
The request for this exemption is in the Publi c Interest as it is safe to assume that there are many consumer applications for the services that can be provided by UAS systems. It is clear that the Congress of the United States, the business sector, and the consumer want to integrate Unmanned Aircraft Systems into the National Airspace System and utilize their unique and cost effective capabilities. It is also in the Public Interest that many of the low level flight operations now conducted by manned aircraft could be accomplished with these light, fire resistant unmanned aircraft that can operate at a fraction of the cost to both the operator and consumer. These aircraft can be operated without risk of loss of life or limb, and without significant financial impact to the operator or any person or property on the ground in the event of the loss of an aircraft. The main focus of UAS flight operation by WesTec Tower Services, Inc is to inspect cell towers, power trans mission lines and petro / chemical plant vertical infrastructure . Utilizing these UASs will create a safer more productive work environment for the climbers , minimize exposure to people and property on the ground, reduce environmentalpollution ( noise & carbon foot print ) and have a positive impact on the local community which is in th e

Public Interest. Finally the petitioner believes that granting this exemption would help to further by Administrators process of integration of UAS systems and possibility help to create additional regulations and guidance to be used as these systems bec ome more widely utilized.



# Abbreviations

**VLOS VISUAL LINE OF SIGHT**
**PIC PILOT IN COMMAND**
**VO VISUAL OBSERVER**
**UAS UNMANNED AIRCRAFT SYSTEM**

Please forward any questions or concerns to the address or email below.

Sincerely, DATE : 5

- 18

- 2015 

# Jacob J Davis

**Jacob Davis / President WesTec Tower Services, Inc**