U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, S.E.

Washington, DC 20590

Petition for Exemption Under 14 CFR § 11.81 to Allow Commercial Use 

of Unmanned Aircraft Systems

TLC Creative

Kevin Bilida, Owner

13428 Maxella Ave #261

Los Angeles, CA 90292

(310) 822-6790

Kevin@tlciscreative.com

To Whom It May Concern:

This application is substantially based on the FAA’s findings in Exemption No. 11977 granted to 

Wiregrass Aerial Photography on July 6, 2015, and in reliance on the analysis provided therein.

1. Sections from which exemptions are sought: Application is hereby made for exemption 

from:

a. FAA Modernization and Reform Act of 2012, PL 112-95 FEB. 14, 2012, Section 

333

b. 14 CFR Part 21, subpart H

c. 14 CFR Part 61.113(a) and (b)

d. 14 CFT Part 91:

i. 91.103(b)(2)

ii. 91.105

iii. 91.109

iv. 91.119

v. 91.121

vi. 91.151

vii. 91.405

viii. 91.407

ix. 91.409

x. 91.417

2. Relief sought: 

a. TLC AiR wishes to operate small Unmanned Aircraft Systems (sUAS) for 

commercial purposes to include (but not be limited to) videography, 

cinematography, photogrammetry, industrial inspections and analyses. This relief is 

sought because commercial use of SUAS is currently prohibited by law unless 

performed under and exemption.

b. This exemption will cover use of the following airframes, all of which will weigh less 

than 55 pounds including payload and energy sources: 

i. DJI Inspire 1

ii. DJI S1000+

iii. DJI Phantom 3

iv. Other models to be added by future amendment to this exemption.

3. Public benefit: 
a. Use of sUAS technology to obtain imagery, information and data currently obtained 

by use of manned flight or manual methods:

i. Reduced statistical risk to human life due to manned aircraft accidents 

(e.g., power line inspections) and due to other dangerous activities that 

can be avoided (e.g., scaffolding/rigging failures during stack or bridge 

inspections).

ii. Reduces the cost of obtaining such information, which benefits 

consumers and the economy.

iii. Reduces environmental impact by eliminating sources of hydrocarbon 

emissions from manned aircraft.

4. Safety not adversely affected:

a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 

and Part 45, Subpart C. 

b. Aircraft will comply with maintenance and inspection requirements of the 

manufacturer. All repair and maintenance work will be conducted or approved by 

qualified personnel such as those authorized by Robotic Skies (or equivalent), and 

will require a test flight after such work. Records of all maintenance and repair work 

will be kept in a maintenance log for each aircraft. 

c. All flight operations will be conducted by at least two individuals (PIC and observer) 

who will maintain verbal communication capability with each other at all times 

during the flight, and who will remain stationary on the ground during the flight 

operations:

i. A Pilot In Command (PIC) who posses the following credentials:

1. An Airman Certificate issued under 14 CFR 61 (private pilot 

license) screened by the TSA

2. A Third Class medical certificate issued under 14 CFR 67.

3. A bi-annual flight review under 14 CFR 61.56

4. A certificate of competency for UAS issued by UMEX (or 

equivalent certification).

5. At least 200 cycles and 25 hours of flight experience in a UAS 

rotorcraft (or UAS fixed-wing in the case of fixed-wing flight 

operations under this exemption). Such cycles and hours may be 

gained during flights under this exemption if a safe distance is 

maintained from persons in accordance with 14 CFR 91.119. 

6. At least 5 hours of flight experience and 3 takeoffs and landings in 

make and model being flown in the prior 90 days. Such cycles and 

hours may be gained during flights under this exemption if a safe 

distance is maintained from persons in accordance with 14 CFR 

91.119.

ii. A Visual Observer.

iii. A Sensor Operator as necessary.

d. All flight operation will be conducted in accordance with valid Certificates of 

Authorization.

e. All flight operations will comply with the following:

i. The manufactures” Aircraft Flight Manuals and Operation Guidelines

ii. TLC AiR flight operations policies including lost communication and 

other emergency and safety procedures.

iii. Conducted in VMC conditions during daylight hours.

iv. PIC and VO will maintain VLOS at all times. 

v. Pre-flight inspections (including ground control station, if any) and safety 

risk assessments will be conducted prior to each flight. 

vi. Flight altitudes will remain below 400 feet above ground level. 
vii. Flight ground speeds will not exceed 50 knots. 

viii. Not intrude into Class B, C or D airspace, or published approach, SID or 

STAR, or take place within 5 nautical miles of an airport. 

ix. Not be made near persons as required in 14 CFR 91.119 and not over 

persons on the ground without their prior permission. 

x. Each flight will be logged in both the PIC's logbook and the aircraft 

logbook. 

xi. Not exceed 75% of the battery or fuel capacity of the aircraft, or 30 

minutes, whichever occurs first. 

xii. Any incidents will be reported to NTSB within 24 hours of occurrence. 

xiii. TLC AiR will maintain liability insurance of at least $1,000,000 issued by 

a major aviation insurance underwriter. 

xiv. Any applicable local FSDO requirements. 

xv. All other applicable regulations concerned with the operation of aircraft. 

f. Aircraft will use 2.4 GHz for control of the aircraft, and 5.8 GHz for sending data 

with well-defined and tested lost link procedures.

Please advise us of any additional information or changes that may be required.

Sincerely,

Kevin Bilida

Owner, TLC AiR

07/14/2015