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 Sy stems (UASs), is request ing to be exempted from the Federal Aviation Regulations (FARs) listed below so Tubreaux Aviation Services, LL C

. 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 o r wychetcoleman@gmail.com 1550 Airport Drive Shreveport, LA 71107
As d escribed below, the requested exemption would permit the operation of lightweight ( less than fift y five pounds (55 lbs. ) total take off gross weight) UASs under controlled conditions for commercial use by professional certificated pilots thereby enhancing safety and fulfill ing the Secretary of Transportation's (the FAA Administrator's) responsibilities to “.... establish requirements for the saf e operation of such aircraft s ys tems in the national airspace s ys tem." Section 333(c) of the Reform Act. Tubreaux Aviation Services, LLC

. respectfull y requests the grant of an exemption to the following specific sections of the Title 14 Code of federal Re gulations 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 p revent Tubreaux Aviation Services, LLC, future commercial use of smallUASs to operate in the national airspace s ys tem as described below. The Reform Act

Section 332 provides for such integration of civil unmanned aircraft s ys tems into our national airspace s ys tem as it is in the public's interest to do so. Tubreaux Aviation Servi ce s ' lightweight UASs meet the definition of "small unmanned aircraft" as defined in section 331 and therefore the integrati on of Tubreaux Aviation Service s ' lightweight UASs are expressl y contemplated b y the Reform Act. Tubreaux Aviation Services would li ke 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 s ys tems may operate safel y in the N ationa l Airspace S ys tem (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 us ers of the NAS , to the public , or pose a thre at 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 o f the operator Reform Act 333 (a) If the secretary

determines that such vehicles "may operate safel y in the National Airspace S ys tem, " the Secretary shall establish requirements for the safe operation of such aircraft i n the N ational Airspace Sy stem. 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 onl y within the line of sight of the pilot within a protected flight area as describ ed below. Such operations will e nsure that the UASs do not creat e a hazard to the users of the National Airspace S ys tem or th e 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 all ow commercial operations of UASs to commence immediatel y. 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 m itigated 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 safet y surrounding the proposed operations, the significant public benefit, including enhanced safety, red uced emissions utilizing UASs verse traditional aircraft as well as the economic impact of greatly reducing the cost of aerial photography thereb y benefiting the greater public's int erest. Accordingl y, 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 purpo ses by Tubreaux Aviation Services, LLC : 1. Flights will be operated in the line

- of

- sight by a ground

- based pilot 2. Flight s 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 wil l be trained as to the applicable portion of the UAS's manual as well as the SOPs. 7. Minimum UAS crew will be one certific ated 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 b y the pilot depending on the mission requirements. 8. Pilot, observer and camera o perator 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 operat ions 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, clo sest 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 pe rsonnel as safet y observers. 10. Tubreaux Aviation Services, LLC, will employ s afety observers as well as sign notifications in areas close to pub lic 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. Tub reaux Aviation Services, LLC, will obtain cons ent (verbal or written) for any pe rsons who need to be within one hundred 100 feet of UAS flight operations. 13. Written and/ or verbal permission from th e relevant property owners will be obtained prior to flight. 14. All r equired permissi ons 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 it s 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: A irworthiness Certificates 14 C.F.R. 91.7(a), 91.203**  **(a)(1)** Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement ofnecessary 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 fro m 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, LL C, meets or exceeds each of these elements. 14 C.F.R. 91.203 (a &b) provides for carrying of civil aircraft certifications and regis trations. 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 o perations center. 14 C.F.R. 91.7(a) prohibi ts 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 b y 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 an y 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 emplo yed 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 gy roscopes 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 indi vidual from beginning a "flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fl y to the first point of intended landin g, 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 F ARs 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 b y 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 previousl y 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 condition s. Tubr eaux Aviation Services, LLC, will only

operate its UASs at or below 400 AGL. Tubreaux AviationServices, 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 op erations. Flights will only

be conducted over private property with consent of the property owner. The equivalent level of safet y 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 be low 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 r egulations 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 p rescribed in P art 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, appl y to Tubreaux Aviation Services, LLC, UASs should its requested exemption be granted. As an equivalent level of safety , Tubreaux Aviation Services, LL C, 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 safet y b y r educing 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 b y batteries and operating at or below 400 AGL they

virtuall y eliminate all of the risk associated with traditional aerialphotograph y. The UASs will carry no people , thereby eliminating the exposure to the

risks associated with fl yi ng while accomplishing the same task in a much safer manner. Granting Tubreaux Aviation Services, LL C, the above exemptions will allow for the expansion of UAS sy stems into the future, in a professional, safety conscious culture steep in the tradition of aviation. The safety culture established b y the founding members of Tubreaux Aviation Services, LLC, is based on our six ( 6 ) years of business experience. Tubreaux Aviation Services, LLC, re spectfull y requests that the FAA grant its exception without delay . The FAA has the authorit y 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").

Sincerel y,

Travis Pierrelee Tubreaux Aviation Services, LLC. Shreveport, LA tpierrelee@suddenlink.net wychetcoleman@gmail.com 318.458.8946

- Travis Pierrelee