May 8, 2015

United States Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act of 2012

Dear Sir or Madam:

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

Act) and C.F.R. Part 11, Tubreaux Aviation Services, LLC. owner and operator of Flight 

School, Aircraft Maintenance and Small Unmanned Aircraft Systems (UASs), is 

requesting to be exempted from the Federal Aviation Regulations (FARs) listed below so 

Tubreaux Aviation Services, LLC. may operate UASs commercially in airspace regulated 

by the Federal Aviation Administration; 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.

The Name and address of the applicant is:

Tubreaux Aviation Services, LLC 

Attn: Travis Pierrelee - tpierrelee@suddenlink.net, 318.458.8946

 or wychetcoleman@gmail.com 

1550 Airport Drive

Shreveport, LA 71107

As described below, the requested exemption would permit the operation of lightweight 

(less than fifty five pounds (55 lbs.) total take off gross weight) UASs under controlled 

conditions for commercial use by professional certificated pilots thereby enhancing safety

and fulfilling the Secretary of Transportation's (the FAA Administrator's) responsibilities 

to “.... establish requirements for the safe operation of such aircraft systems in the 

national airspace system." Section 333(c) of the Reform Act.

Tubreaux Aviation Services, LLC. respectfully requests the grant of an exemption to the 

following specific sections of the Title 14 Code of federal Regulations allowing it to 

operate lightweight UAS's for commercial use:

14 CFR 21, subpart H, 14 CFR 45.23(b), 14 CFR 91.7(a), 91.9 (b)(2),

91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) &(b), 91.405(a),

91.407(a)(1), 91.409(a)(2), 91.417(a) &(b)

Tubreaux Aviation Services, LLC, submits this application in accordance with the 

Reform Act, 112 P.L. 95 331-334, seeking relief from any currently applicable FAR's

operating to prevent Tubreaux Aviation Services, LLC, future commercial use of small
UASs to operate in the national airspace system as described below. The Reform Act

Section 332 provides for such integration of civil unmanned aircraft systems into our 

national airspace system as it is in the public's interest to do so. Tubreaux Aviation 

Services' lightweight UASs meet the definition of "small unmanned aircraft" as defined 

in section 331 and therefore the integration of Tubreaux Aviation Services' lightweight 

UASs are expressly contemplated by the Reform Act. Tubreaux Aviation Services would 

like to operate its lightweight UASs prior to the time period by which the Reform Act 

requires the FAA to promulgate rules governing such aircraft.

The Reform Act directs the Secretary of Transportation to consider whether certain

unmanned aircraft systems may operate safely in the National Airspace System (NAS) 

before completion of the rulemaking required under Section 332 of the Reform Act. In 

making this determination, the Secretary is required to determine which types of UASs 

do not create a hazard to users of the NAS, to the public, or pose a threat to national 

security in regards to the following:

• The UAS's size, weight, speed and operational capability

• Operation of the UAS in close proximity to airports and populated areas

• Operation of the UAS within visual line of sight of the operator Reform Act 333 (a)

If the secretary determines that such vehicles "may operate safely in the National 

Airspace System," the Secretary shall establish requirements for the safe operation of 

such aircraft in the National Airspace System.

Tubreaux Aviation Services, LLC UAS’s are rotorcraft weighing less than 55 pounds

including payload. They operate at a speed of less than fifty knots (50 knots) and have the

capability to hover and move in the vertical and horizontal plane simultaneously. The 

UAS will operate only within the line of sight of the pilot within a protected flight area as 

described below. Such operations will ensure that the UASs do not create a hazard to the 

users of the National Airspace System or the public.

The small nature of the UASs utilized by Tubreaux Aviation Services, LLC, combined 

with the safety protocols outlined below will allow for a greater than equivalent level of 

safety in which Congress envisioned that the FAA must, by exemption allow commercial 

operations of UASs to commence immediately. Also due to the size of the UASs and the 

areas and altitudes they will operate, approval of the exemption presents no national 

security issue and absolutely minimal safety concerns which have been mitigated through 

a rigorous risk management process. Given the clear direction given in Section 333 of the 

Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong 

equivalent level of safety surrounding the proposed operations, the significant public 

benefit, including enhanced safety, reduced emissions utilizing UASs verse traditional 

aircraft as well as the economic impact of greatly reducing the cost of aerial photography

thereby benefiting the greater public's interest. Accordingly, the applicant requests that 

the FAA grant the requested exemption without delay.
The following limitations are considered to be binding for the operation of UASs for 

commercial purposes by Tubreaux Aviation Services, LLC:

1. Flights will be operated in the line-of-sight by a ground-based pilot

2. Flights will operate clear of clouds

3. The UASs will weigh less than 55lbs at take off and during flight

4. Flights will be terminated with 25% of battery life remaining

5. Flights will be operated at an altitude at or below 400' AGL

6. Pilots, camera operators and observers will be trained as to the applicable portion of 

the UAS's manual as well as the SOPs.

7. Minimum UAS crew will be one certificated Commercial pilot or higher rating with a 

current Second Class FAA medical certificate. A camera operator and/or observer may be 

added as required to further reduce the possibility of task saturation by the pilot 

depending on the mission requirements.

8. Pilot, observer and camera operator will maintain real time communication capability

throughout flight operations.

9. The UAS Pilot will conduct a full site survey to determine the Area of Responsibility

(AOR). This AOR is the actual area for UAS operations for a particular day. Each survey

will include the assessment of potential hazards to include but not limited to airspace 

classification, NOTAMS, temporary flight restrictions, closest airport proximity, natural 

and manmade obstacles, and unnecessary persons which may pose a risk to operations or 

safety. If deemed necessary, the crew will employ additional personnel as safety 

observers.

10. Tubreaux Aviation Services, LLC, will employ safety observers as well as sign 

notifications in areas close to public activity.

11. A thorough briefing will be conducted, prior to the first flight of the day in an AOR, 

utilizing the briefing guide in the SOPs. All persons who will be in the AOR while UAS 

flights are conducted will be present for this briefing.

12. Tubreaux Aviation Services, LLC, will obtain consent (verbal or written) for any 

persons who need to be within one hundred 100 feet of UAS flight operations.

13. Written and/or verbal permission from the relevant property owners will be obtained 

prior to flight.

14. All required permissions and permits will be obtained from territorial, state, county, 

parish or city jurisdictions, including local law enforcement, fire or other governing 

governmental agencies.

15. If the UAS loses communications or loses its GPS signal, the UAS will have the 

capability to return to a pre-determined location within the AOR and land autonomously.

16. The UAS will have the ability to abort a flight in case of unpredicted obstacles or 

emergencies.

14 C.F.R Part 21 Subpart H: Airworthiness Certificates 14 C.F.R. 91.7(a), 91.203

(a)(1)

Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of 
necessary airworthiness certificates in relation to FAR 91.203(a)(1) The size, weight and 

defined area of operations for Tubreaux Aviation Services, LLC. UAS flights permits 

exemption from Part 21 because Tubreaux Aviation Services, LLC. meets an equivalent 

level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to 

exempt aircraft from the airworthiness certificate requirement under both the ACT (49 

U.S. C. 44701(f)) and Section 333 of the Reform Act. Both pieces of legislation permit 

the FAA to exempt UASs from the airworthiness certificate requirement in consideration 

of weight, size, speed, maneuverability and proximity to areas such as airports and dense 

populations. Tubreaux Aviation Services, LLC, meets or exceeds each of these elements.

14 C.F.R. 91.203 (a &b) provides for carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons stated above. The equivalent 

level of safety will be achieved by maintaining such certifications and registrations at 

Tubreaux Aviation Services, LLC flight operations center.

14 C.F.R. 91.7(a) 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 C.F.R. 91.9(b)(2) Civil Aircraft Flight Manual in the Aircraft

14 C.F.R. 91.9(b)(2) requires an aircraft flight manual in the aircraft. As there are no 

pilots or passengers, and given the size of the UASs, this regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining an operators manual at the 

flight operations center. The FAA has previously issued exemptions to this regulation in 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602,

10700 and 32827.

14 C.F.R. 91.103(b) Preflight actions

14 C.F.R. 91.103 Each pilot in command shall, before beginning a flight, become 

familiar with all available information concerning that flight. This information must 

include: (b) For any flight, runway lengths at airports of intended use, and the following 

takeoff and landing distance information. This subparagraph is not applicable due to our 

off airfield operations.

14 C.F.R. 91.109 Flight instructions; Simulated instrument flight and certain flight 

tests.

14 C.F.R. 91.109 and all the subparagraphs address the operation of a civil manned 

aircraft in conjunction with training and flight tests. The UAS to be employed by 

Tubreaux Aviation Services, LLC, are not designated in this category.
14 C.F.R. 91.121 Altimeter Settings

14 C.F.R. 91.121 regarding altimeter settings is inapplicable because Tubreaux Aviation 

Services, LLC, UASs utilize GPS systems and internal gyroscopes to provide spatial 

stability and a reference datum.

14 C.F.R. 91.151 Fuel Requirements for Flight in VFR Conditions

14 C.F.R. 91.151 prohibits an individual from beginning a "flight in an airplane under 

VFR conditions unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing, and assuming normal cruising 

speed.

The battery powering the UAS provides approximately 15 minutes of powered flight, 

which is less than the reserve requirement alone by FARs for day. Given the limitations 

on the UAS's flight envelope, proposed AOR size, battery life and its ability to land 

immediately it is reasonable to allow an exception.

An equivalent level of safety can be achieved by limiting flights to 25% of battery power. 

This restriction would be more than adequate to return the UAS to its planned landing 

zone in the AOR.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 

5745, 10673 and 10808.

14 C.F.R. 45.23 Marking of the Aircraft

Applicable Codes of Federal regulations require aircraft to be marked according to 

certain specifications. Tubreaux Aviation Services UASs are (in fact) unmanned; do not 

have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, 

two-inch lettering is impractical to place on such small aircraft. Tubreaux Aviation 

Services, LLC, will, however, place the word "EXPERIMENTAL" on its fuselage as 

required by 14 C.F.R. 45.29 (f) so that the pilot, camera operator, observer and any other 

persons operating in the AOR can see the markings on the UAS. The FAA has previously 

issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167 A, 

and 10700.

14 C.F.R. 91.119 Minimum Safe Altitudes

14 C.F.R. 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. Tubreaux Aviation 

Services, LLC, will only operate its UASs at or below 400 AGL. Tubreaux Aviation 
Services, LLC, will operate its UASs in a defined AOR that has been carefully reviewed 

for hazards and minimizes the presence of any persons not essential for operations. 

Flights will only be conducted over private property with consent of the property owner. 

The equivalent level of safety will be achieved given the size, weight and speed of the 

UAS as well as the location where it is operated. Compared to flight operations with

traditional aircraft or rotorcraft weighing far more than 55lbs, operating below 500 AGL 

with flammable fuel UAS operations present a far smaller risk.

14 C.F.R. 91.405 (a), 407 (a)(1), 409(a)(2), 417(a&b) Maintenance Inspections

These regulations require that an aircraft operator or owner "shall have the aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections, 

except as prescribed in paragraph (c) of this section, have discrepancies repaired as 

prescribed in Part 43 of this chapter, and others shall inspect or maintain the aircraft in 

compliance with Part 43.

These regulations only apply to aircraft with an airworthiness certificate. They will not, 

therefore, apply to Tubreaux Aviation Services, LLC, UASs should its requested 

exemption be granted. As an equivalent level of safety, Tubreaux Aviation Services, LLC,

requires its pilots to conduct a preflight, thorough flight and post flight inspection of the 

UAS to ensure its flight worthiness prior to launch. Each UAS is flown in compliance 

with the applicable manufacturer’s manual to include all software update cycles as well 

as flight checklists. In the event of a malfunction the UAS can land immediately.

Privacy

All flights will occur over private or controlled access property with the property owner's 

prior consent and knowledge.

Summary

Tubreaux Aviation Services, LLC, is seeking exemption from the following rules: 

14 CFR 21, subpart H, 14 CFR 45.23(b), 14 CFR 91.7(a), 91.9 (b)(2), 91.103(b), 91.109,

91.119, 91.121, 91.151(a), 91.203(a)&(b), 91.405(a), 91.407(a)(1), 91.409(a)(2),

91.417(a)&(b).

Approval of the above exemptions allowing commercial operations of small UASs in the 

service of aerial photography will greatly enhance safety by reducing the overall risk 

associated with traditional aircraft. Traditional aerial photography requires large aircraft 

weighing thousands of pounds and carrying hundreds of pound of fuel presenting a 

significant risk to life and property. With Tubreaux Aviation Services, LLC’s use of 

small UASs weighing less than 55 lbs, powered by batteries and operating at or below 

400 AGL they virtually eliminate all of the risk associated with traditional aerial 
photography. The UASs will carry no people, thereby eliminating the exposure to the 

risks associated with flying while accomplishing the same task in a much safer manner.

Granting Tubreaux Aviation Services, LLC, the above exemptions will allow for the

expansion of UAS systems into the future, in a professional, safety conscious culture

steep in the tradition of aviation. The safety culture established by the founding members 

of Tubreaux Aviation Services, LLC, is based on our six (6) years of business experience. 

Tubreaux Aviation Services, LLC, respectfully requests that the FAA grant its exception 

without delay. The FAA has the authority to issue the exemption sought by Tubreaux 

Aviation Services, LLC pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as 

amended (the "Act").

Sincerely,

Travis Pierrelee

Tubreaux Aviation Services, LLC.

Shreveport, LA 

tpierrelee@suddenlink.net

wychetcoleman@gmail.com

318.458.8946 - Travis Pierrelee