1 July 20, 2015 U.S. Department of Transportation Federal Aviation Administration Document Management System 1200 New Jersey Ave., SE Washington, D.C. 20590 RE: Exemption Request to Section 333 of the FAA Report Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 21, s ubpart H , 14 C.F.R. Sections 61.113 (a); 91.7 (a); 91.9; 91.103; 91.105; 91.109; 91. 203 (a) & (b); 91.119; 91.121; 91.151 (a); 91.405(a); 91. 407(a)(1); 91. 409(a)(1) & (2); 91. 417(a) & (b)
Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (Reform Act ) and 14 C.F.R. Part 11, TAC Insight, LLC, herby seeks and applies for an exemption from t he Federal Aviation Regulations listed below, to allow commercial operation of its small unmanned aircraft systems ( s UAS) under the conditions and limitations set forth in this petition. T he requested exe mption would permit TAC Insight, L LC to operate small unmanned aircraft systems (sUAS) under controlled conditions for inspections and photography of construction jobsites, bulk ma terial production facilities and stockpiles, landfills, and debris volume assessments in disaster areas. The sUAS will be operated in a space that (a) is limited, (b) is predetermined, (c) is controlled as to access, and (d) would enhance quality, reduce environmental impacts, and p rovide safety enhancements to the already best practices safety protocols followed TAC Insight, LLC at jobsites. The name and address of the applicant is: TAC Insight, LLC Attn: Mike Mendiola 516 W. Vine Ave Suite 170 Knoxville, TN 37902 PH: 865
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- 2980 Email: mmendiola@tacinsight.com2 REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED

 14 C.F.R. 21, s ubpart H  14 C.F.R. 61.113 (a)  14 C.F.R. 91.7 (a)  14 C.F.R. 91.9  14 C.F.R. 91.103  14 C.F.R. 91.105  14 C.F.R. 91.109  14 C.F.R. 91. 203 (a) & (b)  14 C.F.R. 91.119  14 C.F.R. 91.121  14 C.F.R. 91.151 (a)  14 C.F.R. 91.405(a); 407(a)(1); 409(a)(1) & (2); 417(a) & (b)
APPLICATIONS AND PUBLIC INTEREST TAC Insight, LLC provides professional data management software and services for companies in the heavy civil construction , aggregate production , solid waste, and disaster recovery industries
. There are many applications in these industries in which aerial photography provides a more practical and safer method of acquiring information than ground based alternatives. Examples include but are not limited to: erosion control and containment inspection, material stockpile volume calculations, landfill cell monitoring, and disaster debris surveying. Traditionally the acquisition of aerial photography required fixed or rotary
-winged manned aircraft wi th a pilot and camera operator. The use of sUAS in these applications will offer significant advantages related to safety, time, and cost. Due to their s mall size, weight, and the fact they carry no fuel, the sUAS poses a much lower risk to persons or damage to structures on the ground. Because the sUAS are electric battery powered, they create no harmful emissions and make very little noise. For these rea sons the use of sUAS in the aforementioned applications would be in the public interest.
EQUIVALENT LEVEL OF SAFETY The sUAS to b e used will be the Phantom 3 manufactured by DJI. N o vehicle operated by TAC Insight, LLC will be modifi ed from the manufact urers design unless sp ecifically directed by the same manufacturer. Furthermore, if the submitted exemption is approved, TAC Insight, LLC intends to utilize the sUAS as previously stated above with the following conditions and limitations:3 1. The sUAS will weigh less than 10 pounds. 2. A ll sUAS flights wil l be at or be low 200 feet Above Ground Level (AGL). 3. Operations will occur during daytime Visual Flight Rules (VFR) con ditions only. 4. Maximum total flight time for each flight shall be no more than 20 minutes . Flights will be terminated at 25 % battery power reserve or when low battery level indications are present as indicated in the user manual and safety guidelines. 5. At a minimum, the crew for the sUAS will include the Pilot and a Visual Observer (VO)
. 6. The sUAS Pilot will be the Pilot In Command (PIC). 7. The sUAS PIC will have at least a Private Pilot Certificate and a curren t 3rd Class Medical Certificate or valid US Driver’s License. 8. All flights will be within Visual Line of Sight (VLOS) of the PIC and VO
. 9. The s UAS will remain cl ose enough for the PIC and VO to be capable of seeing the aircraft with vision unaided by any device other than corrective lenses. 10. The sUAS will only operate within the designated area as discussed and planned during the pre
-flight briefi ng. 11. The sUAS will not operate within the following distances from airports or heliports:  5 nautical miles (NM) from an airport having an operational control tower; or  3 NM from an airport with a published instrument flight procedure, but not an operational tower; or  2 NM from an airport without a published instrument flight procedure or an operational tower; or  2 NM from a heliport with a published instrument flight procedure 12. A pre-flight briefing will be conducted prior to each sUAS flight. All personnel involved in the flight are required to be present during this briefing. 13. Prior to each flight, a pre
-flight inspection will be conducted as per the pre
-flight checkli st provided within the sUAS User Manual. 14. The sUAS will not operate d irectly over any persons not directly involved in the operation. 15. The sUAS PIC will obtain the consent of all personnel onsite and within the area and perimeter of the site in which the sUAS will be operating above. 16. Property owners’ approval will be obtaine d prior to sUAS operations on each site. 17. The PIC and VO will be trained in the operation of UAS generally and received up
-to - date information on the specific sUAS that is being operated. 18. At all times voice communications between the PIC and VO will be main tained. 19. If the sUAS loses communications with the ground control station or GPS signal, the sUAS will have the capability to automatically return to the designated landing area. 20. All required permissions and permits will be obtained from territorial, state, county, or city jurisdictions, including local law enforcement, fire, or other appropriate government agencies.4 REGULATIONS REQUIRING EXEMPTION TAC Insight, LLC requests exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the DJI Phantom 3 sUAS: 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1) The sUAS (a) will weigh no more than 10 lbs. gross, (b) will operate within a secured and pre
- determined area, (c) have a maximum operating speed of 100 MPH at altitudes not to exceed 200 feet above ground level , and (d) operate within line of sight of th e pilot in command. 14 CFR § 61.113(a) Private Pilot Privileges and Limitations: Pilot in Command Given the size, weight, speed, range, and operational limitations of the sUAS, TAC Insight, LLC proposes that operators of the sUAS should not be required t o hold a commercial pilot certification. Instead, the PIC should be allowed to hold a private, recreational, or sport pilot certificate. 14 CFR § 91.7(a) Civil Aircraft Airworthiness Prior to each flight, the PIC will inspe ct the sUAS, including the Ground Control Station , and perform the pre
-flight checklist as provided in the sUAS user manual to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the sUAS, the PIC will not operate th e sUAS until the necessary maintenance has been performed and the sUAS is found to be in a condition for safe operation
. 14 CFR § 91.9 ; 91. 203 (a) & (b) Civil Aircraft Fligh t Manual, Certification Given the sUAS has no compartment space to hold a flight manual or oth er documents onboard and given the PIC operates the sUAS from a ground control station, TAC Insight, LLC proposes that all required operator manuals and documentation including exemption and COA be accessible to the PIC during flight operati ons. These documents will be made available to the Administrator or any law enforcement official upon request. 14 CFR § 91.103 Preflight Action This regulation section requires the PIC shall, before beginning a flight, become familiar with all available information concerning that flight includin g runway lengths at airports of intended use and takeoff and landing distance information. Given the sUAS operations will not occur at5 an airfield, TAC Insight, LLC proposes these regulations are not applicable. To provide the equivalent level of safety, t he PIC will complete pre
-flight checklist as directed by the sUAS user manual prior to any flight. 14 CFR § 91.105 Flight Crewmembers at Stations Given the sUAS carries no crewmembers, TAC Insight, LLC proposes this regulation is not applicable. An equivalent level of safety shall be maintained by ensuring that the PIC is identified prior to any flight and the PIC shall maintain control of the sUAS for the duration of the flight. In the event the PIC becomes incapacitated, the sUAS is to automatically ret urn to the designated landing area. 14 CFR § 91.109 Flight Instruction (Dual Controls) Given the sUAS is radio controlled from a ground control station and does not have dual controls by design, TAC Insight, LLC proposes this regulation is not applicable . The equivalent level of safety will be achieved through the sUAS flight training software and by conducting flight training within controlled environments. 14 CFR § 91.119 Minimum Safe Altitudes The regulation provides safe altitude for operation of ci vil aircraft and allows helicopters to operate less than the minimums prescribed. Given the sUAS is a 4 rotor type “quad
-copter” TAC Insight, LLC proposes a request for exemption to operate at altitudes not to exceed 200 feet above ground level or not more than 200 feet above any elevated platform from which takeoff and landing is necessary. Moreover, the sUAS will be operated in a defined and relatively small area and will not be operated over any open
- air assembly of persons. The sUAS will be operated at an altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. 14 CFR § 91.121 Altimeter Settings The regulation in this se ction requires that the PIC navigate to cruise altitudes by means of an altimeter that is set at the elevation of the departure airport or an appropriate altimeter setting available before departure . Given the sUAS utilizes a combination of GPS, barometric pressure, and internal gyroscope readings to calculate altitude, TAC Insight, LLC proposes the PIC use the altitude transmitted by the sUAS to the ground control station.6 14 CFR § 91.151(a) Fuel Requirements for Flight in VFR Conditions Given the limited area of operation and maximum flight time of approxima tely 23 minutes with the man ufacturers current battery pack, TAC Insight, LLC proposes an equivalent level of safety can be achieved by requiring at least 75% battery power in order to begin a flight and requiring the sUAS to return to land when the battery power reaches 25%. 14 CFR § 91.405 (a); 407(a)(1); 409(a)(1) & (2); 417 (a) & (b) Maintenance, Preventative Maintenance, Inspections, and Alterations Referring to maintenance, preventative maintenance, and alterations t o the sUAS, TAC Insight, LLC proposes the operator and/or PIC will provide maintenance and inspections to the sUAS. All maintenance will be conducted and logged in ac cordance with the manufacture’s specifications. Given the size and simplicity of the sUAS combined with the operational and safety guidelines outlined in this petition, an equivalent level of safety can be maintained or exceeded. CONCLUSIONS TAC Insight, LLC respectfully requests that the FAA grant the exemption sought in this petition. TAC I nsight, LLC believes that considering the small size and weight of the sUAS, along with the operating requirements stipulated above, it is demonstrated that the sUAS will be operated safely within the national air space (NAS) with an equivalent or greater level of safety compared to manned aircraft. Sincerely,

Mike Mendiola TAC Insight, LLC