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 May Concern:

Pursuant to Section333 of the FAA Modernization 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 aerial 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 requirements established by the FAA pursuant to Section

333 of the Reform Act.

This exemption would permit commercial operation by TROT, Inc., which uses all

versions of DJI Phantom 3 Pro and 3DR Solo to conduct sUAS support to

news services, real estate photography 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 accordance with TROT, Inc.’s approved Certificate of

Authorization (COA). TROT, Inc. will operate the sUAS's with pilots who are current and qualified
with a FAA Pilot Certificate and only after completing 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 submits 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 confidence 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 convenience, TROT, Inc. has organized this Exemption request as follows:

I. Petitioner's Description

II. Relevant Statutory 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. Petitioner'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 estate 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 compliant and safe environment. TROT, Inc. plans on providing a wide range of services as 

the sUAS market expands. The management 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 sUAS/UAS's pilot holds a Private Pilot Certificate.
The contact information for Petitioner is as follows:

Tilt Rock of Texas, Inc.

8216 Monona Ave

Austin, Texas 78717

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

Form 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 operator.

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".

Additionally, the FAA Administrator 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

statutory 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.

The proposed operations would permit 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 purpose.

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 vertical and

horizontal plane. TROT, Inc. UAS’s will operate in line of sight, during daylight

hours, and will only operate within a sterile area. TROT, Inc. sUAS’s will operate at or 

below 400 feet AGL and will file a NOTAM for each flight operated in controlled airspace that

is required. All required permissions and permits 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 operate, this TROT, Inc. exemption falls within the zone of safety and

demonstrates an equivalent level of safety, in which Congress desired the FAA to permit

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 sUAS's will operate, approval of

the application presents no hazard in the NAS.

Considering the clear direction 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 also in the

public interest.

IV. Description of Proposed Operations

To assist the FAA in its safety assessment of TROT, Inc.’s proposed sUAS
operations, below is a summary of operational limitations and conditions that will ensure an

equivalent or higher level 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 will 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 distance 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 Command will be an FAA licensed airman with at least a private

pilot's certificate, second 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 confined 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 briefing 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 performing 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 by
voice.

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

city jurisdictions, including local law enforcement, fire or other appropriate governmental

agencies.

17. In compliance with the approved 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 terminate 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

emergencies.

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-Way 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

Inspections

A. 14 CFR § 91.103: Preflight Action

TROT, Inc. requests an exemption from the preflight actions requirements of 14
CFR 91.113 that prescribes the preflight actions under which aircraft may operate:

Each pilot in command shall, before beginning a flight, 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, runway lengths at airports of intended use, and the following takeoff

and landing distance information:

(1) For civil aircraft for which an approved Airplane 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 reliable information appropriate to the aircraft, relating to aircraft

performance under expected values of airport elevation and runway slope, aircraft

gross weight, and wind and temperature.

TROT, Inc. will not operate sUAS's under IFR conditions or when the ceilings 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

performance limitations prior to conducting commercial operations.

B. 14 CFR 91.113: Right-of-Way Rules

TROT, Inc. requests 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 right-of-way, the pilot shall give way to that
aircraft and may not pass over, under, or ahead of it unless well clear.

TROT, Inc. operates small pilotless UAS's and cannot comply with these rules as

they have been written.

Equivalent Level of Safety

TROT, Inc. operates sUAS's at or below an altitude of 400 feet AGL, well below

the normal operating altitude of other aircraft. A TROT, Inc. PIC with extensive

aeronautical experience will oversee each mission and has knowledge of the avoid rules. A

Visual Observer 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 less 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 intended operations, the sUAS is normally 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 aircraft, TROT, Inc.’s multi-rotor aircraft weigh a

maximum of 25 pounds, and given the lack of flammable fuel, any risk associated with these

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 operations.

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 of Safety

An equivalent level of safety 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 to
the first point of intended landing, and assuming normal cruising speed -

(1) During the day, to fly after 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 proposed operations within a predetermined 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 terminate 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 the 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, operation 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 91.405(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 exemption 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 inspections will be

performed in accordance with DJI and 3DR User's Manuals. The operator will

ensure that the sUAS is in working order prior to initiating flight, perfom required maintenance,

and keep a log of any maintenance performed. 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 will 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 public 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 petition. 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, photos and unique shots that normal camera aspects 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 requires unique views and expansive panning or extreme altitude with

radical views, the UAS is designed to hold up under demanding conditions. Because of

the autopilot feature with pre-designed mission management and PIC 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 require 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 sterile 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 introduce and demonstrate to farmers of all types that the

sUAS can aid commercial 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 of 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 photo 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 scheduled
maintenance. 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 easily 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 public privacy. TROT, Inc.

knows that many individual have concerns about privacy from the operations 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 determined 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 request allows TROT, Inc. to conduct commercial

operations with small and lightweight unmanned aerial 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 powered 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 of
several regulations and allowing commercial operations. 

Thank you for your time and consideration. We look forward to our future relationship with the FAA and 

this new and promising technology.