AMARILLO

921 North Bivins

Amarillo, Texas 79107

Phone 806.467.0607

Fax 806.467.0622

ARTESIA

408 West Texas Ave.

Artesia, New Mexico 88210

Phone 575.746.8768

Fax 575.748.8905

HOBBS

318 East Taylor Street

Hobbs, New Mexico 88241

Phone 505.393.4261

Fax 505.393.4658

MIDLAND

2901 State Highway 349

Midland, Texas 79706

Phone 432.522.2133 

Fax 432.522.2180

OKLAHOMA CITY

430 West Wilshire, Suite 10

Oklahoma City, Oklahoma 73116

Phone 405.486.7030 

Fax 806.467.0622

SAN ANTONIO

13111 Lookout Way

San Antonio, Texas 78233

Phone 210.265.8025

Fax 210.568.2191

ENVIRONMENTAL CONSULTING

ENGINEERING

DRILLING

CONSTRUCTION

SPILL MANAGEMENT

GENERAL CONTRACTING

Toll Free: 866.742.0742

www.talonlpe.com

July 20, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re:   Request for Exemption Pursuant to PL 112‐95 §333 from 14CFR 21 Part

H, 14CFR 61.3, 14CFR 61.113, 14CFR 91.119, 14CFR 91.121, 14CFR

91.151, 14CFR 91.405, 14CFR 91.407, 14CFR 91.409, 14CFR 91.417

Please consider this a request for an exemption of the above applicable

sections of 14 CFR for Talon/LPE, Ltd. (hereafter ‘Talon/LPE’) for the purpose of

conducting commercial aerial data collection operations with its small

Unmanned Aircraft System (sUAS) within United States airspace. The

employment of sUAS platforms for these missions should provide the FAA with

good cause to find that these operations enhance safety by eliminating the

need to use conventional aircraft in the sometimes unique environments

where a small Unmanned Aerial Vehicle (sUAV) would be particularly adept,

but a conventional aircraft may pose a hazard to its crew and those on the

ground.

Talon/LPE requests exemption from the following applicable regulations,

pursuant to the Administrator’s authority to grant exemptions contained in 49

U.S.C. §106(f), 40113, and 44701:

14 CFR 21 Part H

14 CFR 61.3

14 CFR 61.113,

14 CFR 91.119,

14 CFR 91.121,

14 CFR 91.151,

14 CFR 91.405,

14 CFR 91.407,

14 CFR 91.409,

14 CFR 91.417

AIRCRAFT

Talon/LPE will operate variations of the 3D Robotics X8+, 3D Robotics Solo, 3d

Robotics Aero‐M, DJI Phantom 2, DJI Phantom 3, DJI S900, DJI S1000, Event38

E384, Aeromao Talon, and Aeromao Aeromapper 300. These are commercially

available, off‐the‐shelf UAS. These UAS will weigh no more than 30 pounds and

will operate no faster than 70 knots groundspeed. They are agile, having the

ability to hover, and move about its three axes simultaneously. Because of the

sUAS’s specifications and flight characteristics, it poses no threat to national

security.
US Department of Interior 

Re: Talon/LPE, Ltd. 

July 20, 2015 

Page 2 

AIRWORTHINESS CERTIFICATION

The UAS operated by Talon/LPE will undergo an inspection prior to each flight to ensure

airworthiness. Any damage or malfunction that poses a hazard to flight will be documented and

corrected prior to operation. The UAS carries neither a pilot nor passenger, carries no explosive

materials or flammable liquid fuels, and operates exclusively within visual line of site of the

operator. Operations under this exemption will be tightly controlled and monitored by the

operator. By nature of these conditions, this UAS provides a greater degree ofsafety to the public

and property owners than conventional operations conducted with airworthiness certificates

issued under 14CFR Part 21.

UAS PAYLOAD

Specific payload configurations will vary depending on the mission requirements. In general, the

payload will include a camera and gimbal system, and may include other sensors necessary for

the mission. The UAS will be operated in accordance with manufacturer specifications. Every

flight payload will be documented in the aircraft log. Without a manufacturer’s approved

modification, the UAS will not be operated outside parameters set forth in the manufacturer’s

handbook.

FUEL REQUIREMENTS

(14 CFR 91.151)

The sUAS is powered by a battery, which provides up to 100 minutes of powered flight. Because

of the absence of flammable operating fluids, the sUAS does not pose the same level of risk as a

conventional aircraft. All Talon/LPE operators will terminate flights when remaining battery

power level reaches 20%.

Since no flights conducted by Talon/LPE will require traditional petroleum based fuel, and those

flights will be for less than 100 minutes, Talon/LPE requests relief from 14CFR 91.151.

PREFLIGHT ACTION

Prior to each flight, the operator must conduct a pre‐flight inspection and determine the sUAS is

in a safe condition forflight. The pre‐flight inspection must account for all potential discrepancies,

e.g. inoperable components, items, or equipment. If the inspection reveals a condition that

affects the safe operation of the sUAS, the aircraft is prohibited from operating until the

necessary maintenance has been performed and the sUAS is found to be in a condition for safe

flight. After the pre‐flight inspection, the operator will conduct a pre‐flight safety briefing with

the observer and all other participants.
US Department of Interior 

Re: Talon/LPE, Ltd. 

July 20, 2015 

Page 3 

MAINTENANCE

(14CFR 91.405, 14CFR 91.407, 14CFR 91.409, 14CFR 91.417)

Talon/LPE requests exemption from 14CFR 91.405, 14CFR 91.407, 14CFR 91.409, 14CFR 91.417.

Talon/LPE will conduct all maintenance on the sUAS in accordance with the flight operations

manual, pilot operating handbook, and any guidance received from the manufacturer. Talon/LPE

will abide by all notices from the manufacturer governing the maintenance, preventive

maintenance, and alterations of the sUAS.

There is no certified FAA inspection process for sUAS’s, therefore all inspections will be

conducted by Talon/LPE associates in accordance with manufacturer’s guidelines. These

inspections will be conducted and documented after any maintenance and before every flight. A

functional flight test will be conducted after maintenance and before any flight for hire.

UAS CONTROL

With the exception of the 3D Robotics SOLO, the control of the UAVs will be through a Radio

Transmitter and Receiver provided by the manufacturer and operating on frequency 915 Mhz.

This frequency is FCC approved and provides more than adequate range for operations within

line of sight of the operator. Control of the 3D Robotics SOLO will be through the dedicated Wi‐

Fi link provided by the manufacturer. The UAS is also equipped with flight telemetry radios for

semi‐autonomous operation using highly precise GPS data, while maintaining a constant link

between the vehicle and the ground station. The semi‐autonomous mode is similar to a small

manned aircraft operating with a 3 axis autopilot; operator input is still a function of the system.

(Lost link procedures still apply)

CREW RESOURCE MANAGEMENT (CRM)

All Talon/LPE flight crew members will actively practice CRM in accordance with FAA guidelines.

Further guidance and details are covered in the Talon/LPE training program.

FLIGHT CREW

(14CFR 21 Part H, 14CFR 61.3, 14CFR 61.113)

All flight crew members will successfully complete the Talon/LPE training program and operators

will hold a valid driver's license or third class medical certificate. The Talon/LPE Operator will

remain the individual in charge of each flight and will not transfer responsibility for operational

control of the sUAS aircraft to any other person, unless the flight is specifically for training

purposes and not for hire. Any flight for training purposes will include a visual observer that is

fully qualified for that position.
US Department of Interior 

Re: Talon/LPE, Ltd. 

July 20, 2015 

Page 4 

The Visual Observer will be trained in accordance with the Talon/LPE training program and will

possess a current valid driver’s license issued in the United States.

Talon/LPE requests an exemption from 14CFR 21 Part H until such a time that it has been

established that the Talon/LPE training program is capable of full compliance with the regulation

(Number of successful graduates, certification of instructors, etc).

TRAINING AND CERTIFICATION

(14CFR 61.3 and 14CFR 61.113)

All flight crew members will successfully complete the Talon/LPE training program and operators

will hold a valid driver's license or third class medical certificate. The full Talon/LPE training

program is proprietary in nature and is available to the Administrator upon request. Prior to

operations for hire, the PIC must have accumulated and logged a minimum of 5 hours of total

time as a sUAS pilot with similar sUAS type (fixed wing or rotary). The operator will demonstrate

proficiency in flying the UAS safely in all modes and phases of flight prior to participating in any

for‐hire missions.

OPERATIONS

Talon/LPE operations utilize a sUAS in a manner that provides services not offered by manned

aircraft and enhances the level of safety beyond which can be accomplished by manned aircraft.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and

sensors to conduct aerial data collection, would provide professional services in the following

areas:

1. Aerial photography and/or video for public and/or private use including real estate,

architecture, land mapping, engineering, agriculture, and other related professional

activities.

2. Aerial inspection by photography and/or video of residential/commercial structures

under contract with the owners or local government authority.

3. Aerial inspection by photography and/or video of residential/commercial utility

infrastructure including but not limited to electrical power lines, wind turbines and cell

towers.

4. Aerial inspection by photography and/or video of oil and gas facilities, including pipeline

easements.

5. Aerial video/photography or providing live video feed to assist with search and rescue

operations in cases of an emergency or natural disaster only when the local authorities or

government has requested it by contract or donation.

6. Training to persons individually or belonging to both private and/or public organizations

to increase awareness and improve safety for current and future UAS operations within

the NAS.
US Department of Interior 

Re: Talon/LPE, Ltd. 

July 20, 2015 

Page 5 

Most operations restrict the use of the sUAS to a small area typically encompassing a limited

number ofresidential, commercial, and/orindustrial properties at a time. The structures on these

properties provide sufficient protection from the sUAV, and photography can be completed with

much less risk than what would be incurred in a manned aircraft operation at low altitudes. Our

intended film production operation would typically include both photography and videography

for commercial purposes including corporate events. These events are restricted to only the

invited participants and are closed to the general public, providing the opportunity to operate

only in an area where informed, consenting participants and personnel are present. Talon/LPE

will not operate for the purpose of closed‐set motion picture and television filming. Talon/LPE

will be able to provide a level of safety equal to or greater than the manned aircraft that would

typically provide these services.

Finally, our survey operation includes the orthomosaic mapping of agriculture, construction, and

industrial sites utilizing our sUAS flying pre‐programmed grids that can be interrupted and

returned to a safe landing zone by our operators at any time.

Currently these operations are executed by manned aircraft carrying hundreds of pounds of fuel

and equipment flying at low altitudes and speeds in excess of 100 miles per hour. Our operation

would greatly increase the level of safety, replacing manned aircraft with a sUAV weighing less

than 30 pounds which carries no fuel, and restricted to speeds no greater than 70 knots. These

sites are areas that can readily be secured by Talon/LPE personnel and will not provide any

additional risk to the general public.

The UAS will be operated continuously within the operator’s line of sight, so as not to create a

hazard to users of the NAS or public. In general, the UAS will be operated below 400 feet Above

Ground Level (AGL).

LIMITATIONS

The limitations and conditions that Talon/LPE, agrees to be bound to include:

1. The sUAS takeoff weight will be less than 30 lbs.

2. The sUAS will be operated at less than 70 knots groundspeed.

3. Flights will be operated within unaided visual line of sight of an operator and observer.

4. The sUAS will never be operated directly over a person, and will remain at least 100 feet

from all persons.

5. All flights will be conducted in daylight, Visual Flight Rules (VFR) conditions.

6. Maximum total flight time for each operational flight will be 100 minutes.

7. Flights will be terminated at 20% battery power reserve.

8. Crew for each operation will consist of the UAS Operator, and may include one or more

Visual Observers and a security coordinator.
US Department of Interior 

Re: Talon/LPE, Ltd. 

July 20, 2015 

Page 6 

9. The sUAS operator will be a Talon/LPE trained operator and will hold a valid driver's

license or a FAA third class medical certificate.

10. A briefing will be conducted in regard to the planned sUAS operation prior to each flight.

All Talon/LPE personnel who will be participating in that flight shall be present for the

preflight briefing.

11. Observer and Operator will at all times be able to communicate by voice with each other.

12. When necessary, permission from relevant property owners will be obtained.

13. If the sUAS suffers a ‘lost link’, the sUAS will perform the predetermined flight maneuver

to land as soon as practical as outlined in the preflight briefing.

14. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or

emergencies.

15. All accidents and incidentsshall be recorded in the aircraft log and reported in accordance

with FAA directives.

SUMMARY

Talon/LPE intends to comply with every applicable regulation to the operation of the sUAS. Each

request for exemption has been made with the understanding that Talon/LPE is able to conduct

operations that are at least as safe as or safer than those commercial operations that currently

are conducted by manned aircraft.

Talon/LPE’s proposed exemptions and operational limitations are very closely aligned with other

exemptions already granted.

I appreciate your assistance with this process, as I am aware of the massive undertaking that

these exemption requests are. Please contact me at your convenience with any questions

regarding this request.

Respectfully,

Talon/LPE, Ltd.

Douglas S. Millsaps

Vice President