U.S. Department of Transportation

Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Petition of Tilt Rock of Texas, Inc. (TROT, Inc.) for Exemption Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012.

To Whom It M ay Concern: Pursuant to Section333 of the FAA Modernizatio n and Reform Act of 2012 and 14 CFR Part 11, TROT, Inc. , hereby applies for an exemption from Federal Aviation Regulations (FARs) identified below, to allow commercial operations of small unmanned a erial system (i.e

. sUAS). This exemption is in accordance with protocols outlined in this petition for exemption, the enclosed the UAS manufacturer's operations and/or instructions manual, UAS User's Manuals, UAS Quick Start Guides, and any other requireme nts established by the FAA pursuant to Section 333 of the Reform Act. This exemption would permit commercial op eration by TROT, Inc. , which uses all versions of DJI Phantom 3 Pro and 3DR Solo to conduct sUAS support to news services, real estate photograph y and videography, construction, waterway and land planning and use photography, agriculture, education, oil and gas industry infrastructure inspection, demonstration flights and renewable energy infrastructure inspection

. TROT, Inc

. ’s operation under the exemption will be subject to strict operating requirements and conditions to ensure an equivalent level of safety to currently authorized operations using manned aircraft and under conditions as may be modified by the FAA as required by Section 333.2 TROT, Inc. will be operated under controlled VFR conditions at low altitude in airspace that is permitted in accorda nce with TROT, Inc.’s approved Certificate of Authorization (COA). TROT, Inc. will operate the sUAS's with pilots who are current and qualifiedw ith a FAA Pilot Certificate and only after co mpleting TROT, Inc.’s training

program. Finally, when operating within controlled airspace, the controlling FAA ATC will approve the airspace in which the sUAS will operate in advance. TROT, Inc. respectfully su bmits this request for an exemption because it operates sUAS's. The operations of TROT, Inc. will be conducting will be in lieu of comparatively hazardous operations now conducted with fixed wing and rotary conventional aircraft. The FAA can have confidenc e that the operations will be conducted at an equivalent level or greater level of safety. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator's) responsibilities under Section 333(c ) of the Reform Act to "establish requirements for the safe operation of such aircraft systems in the national airspace system." For your co nvenience, TROT, Inc. has organized this Exemption request as follows: **I. Petitioner's Description II. Relevant Stat**  **utory Authority III. Qualifications for Approval Under Section 333 of the Reform Act**  **IV. Description of Proposed Operations V. Regulations From Which Exemption is Requested**  **VI. Public Interest VII. Privacy**  **VIII. Federal Registry Summary IX. Conclusion**  **I. P etitioner's Description**  Tilt Rock of Texas, Inc. , headquartered in Austin , Texas, is a company that provides project management services for development companies in the residential, commercial, industrial and renewable energy sector. We are adding to our services, sUAS support to news services, real esta te photography and videography, construction , waterway and land planning use photography, agriculture, education, oil and gas industry infrastructure inspection , renewable energy infrastructure inspections and demonstration flights in a com pliant and safe en vironment. TROT, Inc. plans on providing a wid e range of services as the sUAS market expands. The man agement at TROT, Inc. has over 30 years of experience in the construction industry and in the aviation industry from gliders & ultralights in the 80s to private pilot single engine in 2000s. Our sU AS/UAS's pilot holds a Private Pilot Certi fi cate.The contact inform ation for Petitioner is as follows:

Tilt Rock of Texas, Inc. 8216 Monona Ave Austin, Texas 78 717 **II. Relevant Statutory Authority** This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act. Congress has directed the FAA "to safely accelerate the integration of civil unmanned aircraft systems into the national airspace system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to consider whether certain unmanned aircraft systems may operate safely in the National Airspace ("NAS") before completion of the F orm 1a UAS rulemaking, based on the following considerations: • The UAS's size, weight, speed, and operational capability; • Operation of the UAS in close proximity to airports and populated areas; and • Operation of the UAS within the visual line of sight of the ope rator. If the Secretary determ ines 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". Additionally, the FAA Administra tor has general authority to grant exemptions from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. A party requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it would provide a level of safety at least equal to the existing rules). The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This
statu tory authority, by its terms, includes exempting civil aircraft, as the term is defined under 40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service: The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections.**III. Qualifications for Approval Under Section 333 of the Reform Act** 

The proposed operations in this petition for exemption qualify for expedited approval under Section 333 of the Reform Act. Each of the statutory criteria and other relevant factors are satisfied. Th e proposed operations would perm it TROT, Inc. the use of small UAS’s under controlled conditions in airspace that is: (1) predetermined; (2) controlled as to access; and that (3) provides an increased level of safety beyond that existing when fixed or rotor wing aircraft are used to accomplish the same purpos e. TROT, Inc. uses UAS’ s that are multirotor and fixed wing airplanes, weighing less than 55 pounds including payload. They operate, under normal conditions, at speeds not to exceed 50 mph. The multirotor has the capability to hover and move in the vertica l and horizonta l plane. TROT, Inc. UAS’ s will operate in line of sight, during daylight hours, and will only operate within a ste rile area. TROT, Inc. s UAS’ s will operate at or below 400 feet AGL and will file a NOTAM for each flight operated in controlle d airspace that is required. A ll required permissions and perm its will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies prior to operating a sUAS. Given the small size of the sUAS’s involved and the restricted sterile environment within which they will opera te, this TROT, Inc. exemption falls within the zone of safety and demonstrate s an equivalent level of safety, in which Congress desired the FAA to perm it commercial UAS operations by exemption pending completion of formal rulemaking. Also, due to the size of the sUAS's and the confined area in which these s UAS's will operate, approval of the application presents no hazard in the NAS. Considering the clear d irection in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, and the significant public benefit, the grant of the requested exemptions is als o in the public interest. **IV. Description of Proposed Operations** To assist the FAA in its safety assessment of TROT, Inc.’s proposed sUASoperations, below is a summary of operational limitations and conditions that will ensure an

equivalent or higher leve l of safety to operations conducted under current regulatory guidelines: 1. The sUAS will weigh less than 55 pounds. 2. Flights will be operated within line of sight of the PIC and visual observer. 3. Maximum total flight time for each operational flight w ill be limited to the amount of time the sUAS can be flown and still maintain a reserve battery power or fuel quantity of no less than 25%. 4. Flights will be operated at an altitude of no more than 400 feet AGL. 5. Flights will be operated at a lateral di stance of least 100 feet from any inhabited structures, buildings, vehicles, vessels, people not associated with the operation or who have not signed a waiver in advance of the operation. 6. Minimum crew for each operation will consist of the sUAS Pilot in Command and a Visual Observer when operating with the use of FPV equipment. Additional crewmembers may consist of a Pilot and a Camera Operator. 7. The sUAS Pilot in Comm and will be an FAA licensed airman with at least a private pilot's certificate, secon d class medical, and a current check required by14 CPR Part 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 8. TROT, Inc. will designate a Pilot in Command ("PIC") for each mission. 9. The sUAS will operate only within a co nfined sterile area. 10. Prior to the operations at a particular location, a site inspection will have been conducted. On the day of the mission the management person with operational control and the PIC will concur on dispatching of the mission. 11. A bri efing will be conducted in regard to the planned sUAS operations prior to each day's missions. It will be mandatory that all personnel who will be perfor ming duties within the boundaries of the sterile area be present for this briefing. 12. TROT, Inc.’s crew will use the checklist and callouts. 13. All sUAS's will be maintained in compliance with the manufacturer's and Company guidelines. 14 . Pilot in Command and Visual Observer will at all times be able to communicate byvoi ce.

15 . Pilot in Command, Pilot, Camera Operator, Visual Observer, and Operational Personnel will have been trained and tested in accordance to TROT, Inc.’s UAS Aircraft Training Manual. 16 . A ll required permissions and perm its will be obtained from territorial, state, county or city jur isdictions, including local law enforcement, fire or other appropriate governmental agencies. 17 . In compliance with the approv ed Waiver, TROT, Inc.’s management will submit a written "Plan of Activities" to the local Flight Standards District Office (FSDO ) having jurisdiction over the area of proposed filming three days in advanced of operations during film or movie productions. 18 . If the sUAS loses communications signal, the sUAS will have the capability to return to a pre

- determined location within the Sterile Area and land. 19 . Contingency plans will be in place to safely term inate flight if there is a loss of communication between the pilot and the observer. 20 . The sUAS has the capability to abort a flight in case of unpredicted obstacles or emergenci es. 21 . TROT, Inc. will assure no individuals' privacy is violated. 22 . ATC will be contacted prior to operating in airspace other than G. V. Regulations From Which Exemption is Requested A. 14 CFR § 91.103: Preflight Action B. 14 CFR § 91.113: Right

-of

-W ay Rules C. 14 CFR § 91.119 (c): Minimum Safe Altitudes D. 14 CFR § 91.121: Altimeter Settings E. 14 CFR § 91.151 (b): Fuel Requirements for Flight in VFR Conditions F. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspecti ons A. 14 CFR § 91.103: Preflight Action TROT, Inc. requests an exemption from the preflight actions requirements of 14CFR 91.113 that prescribes the preflight actions under which aircraft may operate:

Each pilot in command shall, before beginning a fligh t, become familiar with all available information concerning that flight. (a) Flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed , and any known traffic delays of which the pilot in command has been advised by ATC; (b) For any flight, run way lengths at airports of intended use, and the following takeoff and landing distance inform ation: (1) For civil aircraft for which an approved A irplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and (2) For civil aircraft other than those specified in paragraph (b )(1) of this section, other reliabl e inform ation appropriate to the aircraft, relating to aircraft perform ance under expected va lues of airport elevation and run way slope, aircraft gross weight, and wind and temperature. TROT, Inc. will not operate sUAS's under IFR conditions or when the ce ilings are below 1000 feet and the visibility is below 3 statute miles. Neither DJI nor 3DR sUAS 'shave published approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data. Equivalent Level of Safety TROT, Inc. will ensure that the weather will be adequate to complete the mission in VFR condition. When TROT, Inc. operates at a high altitude location, the UAS will be test flown at gross weight to test perform ance limitations prior to conducting commercial operations. B. 14 C FR 91.113: Right

- of

-Way Rules TROT, Inc. request s an exemption from 14 CFR 91.113 Right

- of

-way rules, requiring vigilance by each person operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives another aircraft the rig ht

- of

-way, the pilot shall give way to thataircraft and may not pass over, under, or ahead of it unless well clear.

TROT, Inc. operates small pilotless UAS's and cann ot comply with these rules as they have been written. Equivalent Level of Safety TROT, In c. operates sUAS's at or below an altitude of 400 feet AGL, well below the normal operating altitude of other ai rcraft. A TROT, Inc. PIC with extensive aeronautical experience will oversee each mission and has knowledge of the avoid rules. A Visual Observe r will assist the PIC in looking for aircraft entering the operations area. It's the responsibility of the PIC to cease operations and land the UAS immediately whenever and aircraft comes into the vicinity creating a potential threat. Operations cannot recommence until the threat is clear. C. 14 CFR. § 91.119: Minimum Safe Altitudes TROT, Inc. requests an exemption from the minimum safe altitude requirements of 14 CFR 91.119 that prescribes the minimum safe altitudes under which aircraft may operate: • Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. • Over other than congested areas at an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or
structure. Section 91.119 (d) allows for a helicopter to operate at l ess than those minimum altitudes when it can be operated "without hazard to persons or property on the surface," provided that "each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA." To provide the inten ded operations, the sUAS is norm ally operated below 400 feet AGL. Additionally, due to the nature of the proposed operations, the sUAS will maintain a lateral distance of at least 100 feet from inhabited structures, buildings, vehicles, and vessels, and from people not associated with the operation.**Equivalent Level of Safety**

Compared to flight normal a ircraft, TROT, Inc.’s multi

- rotor aircraft weigh a maximum of 25 pounds, and given the lack of flammable fuel, any risk associated with t hese operations is far less than those that presently exist with conventional aircraft. An 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. The sUAS will be operated in a sterile area, where buildings and people will not be exposed to operations without their pre

- obtained consent. Because of the advance notice to the property owners and participants, all affected individuals will be well aware of the planned flight operat ions. Furthermore, by operating at such lower altitudes, the sUAS will not interfere with aircraft that are subject to the minimum safe altitude regulations. Finally, the successful safety record of the DJI and 3DR sUAS's demonstrates that the sUAS can be safely used at these lower altitudes and closer operating environments. D. 14 C.F.R. § 91.121: Altimeter Settings TROT, Inc. seeks an exemption from 14 CFR 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. An exemption is required because some of the sUAS aircraft do not have a barometric altimeter, but rather a GPS altitude read out. **Equivalent Level o f Safety**  An equivalent level of sa fety will be achieved in that TROT, Inc. will confirm the altitude of the launch site shown on the GPS altitude indicator before flight. Moreover, the PIC will use the GPS altitude indicator to constantly monitor the sUAS' s height, thus ensuring operation at safe altitudes. E. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions TROT, Inc. requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for flight in VFR conditions. Section 91.151 states: (a) No person may begin a flight in an airplane under VPR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly tothe first point of intended landing, and assuming normal cru ising speed

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(1) During the day, to fly a fter that for at least 25 minutes; or (2) At night, to fly after that for at least 45 minutes. The batteries powering TROT, Inc.’s UAS's provide approximately 10

- 18 minutes of powered flight. To meet the 30 minutes reserve requirement in 14 CPR 91.151, sUAS flights could not be conducted. Given the limitations on the sUAS's proposed flight area and the location of its propos ed operations within a predeterm ined area, a safety margin based on a reserve amount of battery life is needed. TROT, Inc. will not be conducting any sUAS flights at night. Equivalent Level of Safety An equivalent level of safety will be achieved because the operations will be conducted on

- site without significant transit time by the sUAS. All flights will be planned to term inate with no less than 25% reserve battery power still available. This restriction would be more than adequate to return the sUAS safely to its planned landing zone from anywhere in its confined area of operation even in t he event of an unexpected occurrence . Operation of the sUAS with less than 30 minutes of reserve fuel does not include the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS, and the proximity of the flight operation to the landing zone. Moreover, o peration will be limited to controlled areas where only people and property owners, or official representatives who have signed waivers will be allowed. F. 14 CFR § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections TROT, Inc

. also seeks an exemption from the maintenance inspection requirements contained in 14 CPR 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 CPR Part 43. 14 CPR 91.40 5(a) stating that each owner or operator of an aircraft "shall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections ... have discrepancies repaired as prescribed in part 43 of this chapter"). An exempti on to these regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which the sUAS will not have.Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and i nspections will be perform ed in accordance with DJI and 3DR User's Manuals. The operator will ensure that the sUAS is in working order pri or to initiating flight, perfom required maintenance, and keep a log of any maintenance perform ed. The operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. If mechanical issues arise, the sUAS's size and carrying capacity, and the fact that flight operations wi ll only take place in restricted areas for limited periods of time during daylight hours, creates less risk than that associated with conventional rotorcraft performing the same operation. VI. PUBLIC INTEREST Granting TROT, Inc. an exemption furthers the p ublic interest. National policy set by Congress favors early integration of UAS into the national airspace in controlled, safe working environments such as those propose in this petitio n. The vision of TROT, Inc. is to help facilitate the safe integration of sUAS's into mainstream USA in the following areas: **• Training** To ensure that UAS Operators are properly trained and certified to safely operate the particular type of sUAS aircraft. Also, training will be conducted in the type of operations they will be using their aircraft. **• Real Estate** The sUAS can be used in all areas of real estate, including commercial, residential and industrial properties. Using a sUAS, real estate professionals can create promotional videos, p hotos and unique shots that norm al camera as pects cannot capture. TROT, Inc. easy-to

- use video and photo platform enables properties to stand out, providing dazzling views that are typically shown via expensive computer animation or costly helicopter rentals. Imagine shooting a view from a high

- rise condo in stunning high definition that shows your potential customer the actual view from the residence.The remote platform is great for new planning, zoning and large developments. Simple

and easy

-to

- use video and photos allow for multiple height pictures and elevation views. **• Cinematography** Whether the shot require s unique views and expansive pann ing or extreme altitude with radical views, the UAS is designed to hold up under demanding conditions. Because of the autopilot fea ture with pre

- d esigned mission management and P IC control interrupt, the pilot and camera operator can easily create the ultimate shot with HD video or HD still photos. **• News Gathering** Similar to movies and videography, each news assignment may requi re a completely different shot or view of a scene. With budgets for traditional helicopter use being greatly reduced, the UAS is the perfect solution to allow for easy news gathering for a fraction of the cost. The sUAS can and will be operated in a steri le area away from the public, while the traditional helicopter must hover over persons and property increasing the danger to individuals. **• Agriculture and Conservation** TROT, Inc. would intro duce and demonstrate to farm ers of all types that the sUAS can aid comm ercial agriculture, land management and conservation efforts by assessing crops, mapping flood zones, measuring snow pack and more. The sUAS can fly pre - saved missions via the fully automated ground station, which allows for time

- lapse photos o f fields, crops and known land tracts. It also can accurately recreate the same pattern during all seasons, providing invaluable data for land and soil management. Using HD video, HD photos, and IR cameras allows for detailed analysis and recording. With p hoto rendering software, 3D maps and topography can be used in conjunction with time

- lapse photos to create highly detailed maps for erosion, flood mapping and other critical aspects of land management. **• Oil and Gas Industry Infrastructure Inspection** TROT, Inc. will use HD video, HD photos and IR cameras to inspect critical oil and gas infrastructures allowing detailed analysis prior to scheduledmaintenance. This analysis will enable repair crews to minimize down

-time which in turn

greatly improve production efficiency.

 **Renewable Energy Infrastructure Inspection**  TROT, Inc. will use HD video, HD photos and IR cameras to inspect and promote Solar Energy, Wind and Ocean Wave infrastructure. Some of these remote and dangerously high locations can be easil y and safely accessed by sUAV and reduce, if not eliminate in some cases, the human exposure currently used to provide these services. VII. Privacy TROT, Inc. is committed to protecting the publi c privacy. TROT, Inc. knows that many individual have concern s about privacy from the o perations of sUAV’s

. TROT, Inc. will inform residents, commercial property owners, churches, schools, and governmental organizations of our intent to conduct commercial drone operations in proximity to their property. VIII. Federal Registry Summary Pursuant to 14 CPR Part 11, the following summary is provided for publication in the Federal Register, should it be determ ined that publication is needed: TROT, Inc. seeks an exemption from the following rules: 14 CPR 91.103; 14 CPR 91. 113; 14 CPR 91.119; 14 CPR 91.121; 14 CPR 91.151(a); 14 CPR 91.405(a); 14 CPR 91.407(a)(1); 14 CPR; 91.409(a)(2); 14 CPR 91.417 (a) & (b). Approval of this exemption requ est allows TROT, Inc. to conduct commercial operations with small and lightweight unma nned aeria l systems. TROT, Inc. is committed to safety, education, and solutions, which enhance safety of sUAS operations in the NAS while reducing risk to the general public and property owners. TROT, Inc. uses sUAS, weighing less than 55 pounds and powe red by batteries and small amounts of fuel. This eliminates virtually all of that risk given the reduced mass and lack of large amounts of combustible fuel carried on board as compared manned aircraft. The sUAS is transported to the designated mission area and set up there. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation of these small UAS will provide an equivalent level of safety, supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements ofseveral regulations and allowing commercial operations.

Thank you for your time and consideration . We look forward to our future relationship with the FAA and this n ew and promising technology.