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February 23, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave. SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act

Dear Sir/Madam,

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

Act), and 14 C.F.R. Part 11, Tigerhill Studio Corp., doing business as Tigerhill Studio 

(“Tigerhill”), based in Illinois and operating Small Unmanned Aircraft System (sUAS) 

equipped to conduct aerial photography and video services for various industries, 

hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed 

below to allow operation of our sUAS commercially in airspace regulated by the Federal 

Aviation Administration (FAA) so long as such operations are conducted with and under 

the conditions outlined herein or as may be established by the FAA as required by 

Section 333. The requested exemption is similar to previous FAA issued grants of 

exemption including but not limited to Exemption Nos. 11062, 11109, 11112, 11213, 

11295, 13565, and 14781.

Operator:

John Hill, President, Certificate Number 3840442

Tigerhill Studio

6607 Weather Hill

Willowbrook, IL 60527

708-246-3566

John@TigerhillStudio.com

www.TigerhillStudio.com

SD VOB Service Disabled Veteran-Owned Business

Certificate Number 3840442

Our commercial activities would include:
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The requested exemption would permit Tigerhill to pursue its commercial interests in

providing services to consumers interested in training, research, and aerial data capture 

using small advanced sUAS in the following areas:

• Aerial Photography and Videography for the real estate, construction, and other 

industries

• Agricultural and Construction Surveying and Applications

• Product Demonstrations

• Research and Development

All Tigerhill sUAS flights that will occur over private or controlled access property will do 

so with the property owner's prior consent and knowledge. Only people who have 

consented or otherwise have agreed to be in the area where photography and 

videography will take place will be captured in any photos or videos.

Additionally, all Tigerhill pilots will hold an airline transport, commercial, private,

recreational, or sport pilot certificate and also hold a current FAA airman medical 

certificate or a valid U.S. driver’s license issued by a state, the District of Colombia, 

Puerto Rico, a territory, a possession, or the Federal government. If an observer is not a 

qualified pilot, they will be trained by Tigerhill pilots to understand the proper roles of an 

observer, communication procedures, proper visual scan techniques, operations at nontowered airports, and appropriate sections of the Aeronautical Information Manual.

The Petitioner Requests Relief From the following regulations:

Regulations from which the exemption is requested: 14 CFR §§ 61.23(a) and (c), 

61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.109, 91.119(c), 91.121, 

91.151(a)(1), 91.215, 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 Tigerhill to operate a UAS to perform training, 

research, and aerial data collection.

We are petitioning for exemption to enable Tigerhill to operate a series of UAS platforms 

that have been previously approved by exemption. Namely:

Turbo Ace Infinity 6 - Exemption 13382

DJI Phantom 2 - Exemption 11398

DJI Phantom 2 Vision - Exemption 11310

DJI Phantom 2 Vision+ - Exemption 11398

DJI Inspire - Exemption 11398

DJI S1000 - Exemption 11416

DJI S900 - Exemption 11401

DJI Phantom 3 Professional - Similar to Exemption 11310

DJI Phantom 3 Advanced - Similar to Exemption 11398

Flamewheel 550 - Exemption 11397
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eBee AG - Exemption 11339

3DRobotics IRIS+ - Exemption 11419

RF-70 - Exemption 11295

These sUAS all weigh less than 55 lbs,, have a built- in capability to limit the height 

flown above the ground, to limit the radius of the distance it flies from the operator and to 

exclude it from Class B, C and D airspace including a no fly zone feature. Each system 

also has the failsafe function of the autopilot system, which means when the 

communication between the Main Controller and the transmitter is lost, the system will 

automatically trigger Return to Home and will land safely. This submission does not 

include the Operating Manuals for each model requested above, as they have been 

reviewed by the Administrator in granting previous exemptions. Model specifics are 

listed in the Tigerhill Operating Manuals which are not included with this submission..

Copies of all Operating Manuals for the individual models listed will be submitted on 

request. 

The above specifications meet standards listed below:

• Tigerhill will only operate its sUAS in line of sight of a pilot and/or observer and will 

operate at sites that are a 'sufficient distance' from populated areas within the sterile 

area described in the operator’s manual. Such operations will insure that the sUAS will 

"not create a hazard to users of the national airspace system or the public."

• Tigerhill will not operate sUAV within 5 nautical miles of an airport reference point 

(ARP) as denoted in the current FAA Airport/Facility Directory (AFD), unless a letter of 

agreement with that airport’s management is obtained or otherwise permitted by a COA 

issued to Tigerhill.

• Maximum flight time for each operational flight will be 60 minutes.

• Flights will be terminated at 25% battery power reserve should that occur prior to the 

60 minute limit.

• The sUAV will be programmed so that it will not be operated at an altitude of no more 

than 400 feet AGL.

• Minimum crew for each operation will consist of the sUAS Pilot and the Visual 

Observer.

• The sUAS PIC's (Pilot in Command) will be an airline transport, commercial, private,

recreational, or sport pilot certificate and also hold a current FAA airman medical 

certificate or a valid U.S. driver’s license issued by a state, the District of Colombia, 

Puerto Rico, a territory, a possession, or the Federal government.
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• The sUAS operated by the petitioner weighs less than 55 pounds, including the 

payload (i.e. camera, lens, and gimbal).

• The sUAS will operate at speeds of no more than 55 knots.

• Given the small size of the sUAS and the restricted sterile environment within which 

they will operate, our sUAS operations adhere to the Reform Act's safety requirements.

Additionally, the fact that the Tigerhill pilots hold FAA Pilot certificates demonstrates that 

they have a high regard for safe operations with an understanding of FARs, pre-flight 

inspections, maintenance and repair, operations within airspace, as well as being trained 

to high safety standards.

Under the requested exemption, Tigerhill will ensure that all operators have completed a 

small unmanned aircraft systems (UAS) education and training program including all 

applicable regulations and guidance documents; including aeronautical background 

information such as charts, NOTAMS and Aircraft Circulars; Radio Communications 

Procedures; Human Factors and Crew Resource

Management; Basic Small UAS Aerodynamics; Weather factors; Airmanship and 

Decision-making and Safe Operating Procedures.

We respectfully request exemption under Section 333 to enable to operate safe, low-risk

commercial sUAV operations for the activities stated. Tigerhill at all times will respect the 

space and privacy of citizens and property whilst keeping our skies safe.

Exemption Requests and Equivalent Level of Safety

Tigerhill requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the sUAV System:

14 CFR 61.23 Medical Certificates

The regulation provides that a person requires a first or second class medical to act as 

pilot in Command of an aircraft for compensation or hire. Our proposed operations 

require that the PIC must hold a current FAA airman medical certificate or a valid U.S. 

driver’s license issued by a state, the District of Colombia, Puerto Rico, a territory, a 

possession, or the Federal government. Since the aircraft cannot carry passengers or 

property, we feel we meet the intent of 61.23 even though the intent of this application is 

to conduct a business.
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14 CFR 61.101, 14 CFR 61.113, and 14 CFR 61.315 Pilot privileges and Limitations

The regulation provides that no person that holds a Recreational Pilot, Sport Pilot, or 

Private Pilot certificate may act as pilot in Command of an aircraft for compensation or 

hire. Our proposed operations require that the PIC must hold at least airline transport, 

commercial, private, recreational, or sport pilot certificate. Since the aircraft cannot carry 

passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even 

though the intent of this application is to conduct a business.

14 CFR 91.7 Civil Aircraft Airworthiness

This Section prohibits the operation of an aircraft without an airworthiness certificate. As 

no such certificate will be applicable in the form contemplated by the FARs, this 

Regulation is inapplicable.

14 CFR 91.119 Minimum safe altitudes: General

The regulation states that over sparsely populated areas the aircraft cannot be operated 

closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical 

mission of the sUAS would be photography or survey of persons, vessels, vehicles or 

structures, it would be necessary to operate closer than 500 feet to the items listed. 

Operations will only be flown over property or persons where permission has been 

obtained and careful pre-planning has been performed. The aircraft will be operated at a 

low altitude allowing, if a power unit fails, an emergency landing without undue hazard to

persons or property on the surface. Therefore we maintain that due to the small size of 

the UAS, the hazard to persons, vehicles and structures is minimal compared to manned 

aircraft, which should be considered in granting the exemption.

14 CFR 91.121 Altimeter settings

The regulation requires that aircraft shall maintain cruising altitudes by reference to an 

altimeter setting available within 100 NM of the aircraft. The sUAS will always fly below 

400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict 

with other aircraft. An Above Ground Level altimeter measurement above the takeoff 

point is transmitted via radio from the sUAS on-board computer to the display screen 

held by the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions
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The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to 

fly after that for at least 30 minutes. We feel the intention of this paragraph is to provide 

an energy reserve as a safety buffer for delays to landing. The sUAS are battery 

operated and the maximum duration of flight from a single battery charge is 12-45 

(depending on which sUAS) minutes with a 20% reserve. Since the aircraft will

never fly more than 1/2 NM from the point of intended landing, a full battery charge at 

launch will ensure that we meet the reserve energy requirement of this paragraph. We 

request an exemption to the word "fuel" and ask for an equivalent interpretation with the 

word "energy". We also request exemption from the 30 minute reserve and ask that our 

reserve will be to fly the mission to the point of intended landing and have at least a 20% 

battery reserve after that.

14 C.F.R. 91.215 ATC transponder and altitude reporting equipment and use:

This regulation states all aircraft operating within 30 nautical miles of class A, B and C 

airspace must be equipped with automatic pressure altitude reporting equipment having 

a Mode C capability that automatically replies to Mode C interrogations. Due to the small 

size and lifting capabilities of our UASs, we cannot carry a traditional transponder. All of 

our operations will be under 250’ if we are operating within the 30 mile reach of a Mode 

C veil.

14 CFR Subpart E (91.401- 91.417) - Maintenance, Preventive Maintenance, 

Alterations.

The regulation provides that the operator is primarily responsible for maintaining the 

aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 

91.407 and 91.409 require that the aircraft be "approved for return to service by a 

person authorized under 43.7" after maintenance and inspection. It is our intention that 

the PIC perform maintenance and inspection of the aircraft and "be authorized to 

approve the aircraft for return to service."

The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in 

addition, conduct detailed inspections after every two hours of flight. Maintenance 

performed by the PIC is limited to repairing small cracks, replacing a propeller, checking 

electrical connections and updating software and firmware for the on-board computer. 

All other maintenance will be performed by the manufacturer or their designated repair 

facility. The PIC will document work performed in accordance with 91.417. We feel that 

due to the size, construction, and simplicity of the aircraft, the PIC can ensure

an equivalent level of safety.

How this Request is to the Betterment of our Community
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Tigerhill believes that the use of UAS to perform agricultural land imaging creates a

benefit to the public. The ability to use an onboard geo-referenced still camera to collect 

high-resolution data that can be used to increase crop production and reduce 

unnecessary chemical use will provide a less expensive and healthier food supply to the 

public. The unmanned aircraft does not carry any persons or flammable liquids, reducing 

public exposure in the event of an incident. Finally, the unmanned aircraft can be 

launched and recovered from the property which we have been contracted to image. 

The ability to avoid overflying private and public properties provides the public with the 

benefit of privacy from aircraft flying overhead. Unmanned Aircraft Systems (sUAS) are 

also a feasible method to obtain information of agricultural cropland to determine 

optimum inputs that result in cost savings to farmers, yield security, and reduce

environmental impact of excess fertilizers and chemicals in the soil. Similar reasoning 

applies to the use of UAS for real estate, construction, infrastructure, and events.

Request for Blanket COA Approval

On March 24, 2015, the FAA announced that it has implemented a new policy of 

granting "blanket" COAs to applicants requesting exemptions from the Federal Aviation 

Regulations under Section 333 of the FAA Modernization and Reform Act of 2012.

The Applicant hereby requests that a "blanket" COA that conforms to the terms set forth 

in https://www.faa.gov/news/updates/?newsId=82245 upon approval of Tigerhill’s 

exemption request.

Sincerely,

John Hill, President

Tigerhill Studio

6607 Weather Hill

Willowbrook, IL 60527

708-246-3566

John@TigerhillStudio.com

www.TigerhillStudio.comSD VOB Service Disabled Veteran-Owned Business