September 14, 2015

U.S. Department of Transportation Docket Management System 

1200 New Jersey Ave., SE 

Washington DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 

91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 

91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and 

(2); 14 CFR 91.417(a) and (b) 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 

CFR Part 11, TecNspecT, LLC., operator of an Unmanned Aircraft System (UAS), hereby applies for an 

exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its 

UAS, so 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. 

Name and Contact Information of Applicant: 

TecNspecT, LLC PO 1105 Meadow Bridge Lane, Arrington, TN 37014; 615-943-0798 

Prichey0405@comcast.net 

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 

CFR 91.103 14 CFR 91.109 14 CFR 91.119 (c) 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 

CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & (b) 

Scope of Operations: 

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

would operate in the following manner: 

 Aerial photography and/or video for public and/or private use including real estate, architecture, land 

surveying, engineering and other related professional activities. 

 Aerial photography and/or video for public and/or private use including television, public events,

cinematography and news gathering 

 Aerial inspection/photography of residential/commercial structures under contract with the owners or 

local government authority. 
 Aerial inspection/photography of residential/commercial utility infrastructure including but not limited

to electrical power lines, wind turbines and cell towers. 

 Aerial video/photography or providing live video feed to assist with search and rescue operations in

cases of an emergency or natural disaster when local authorities or government has requested it by 

contract or donation. 

 The ability to offer training to persons individually or belonging to both private and/or public 

organizations that have interests in the use and application of a UAS for the purpose of the safe 

operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as for the 

protection of the persons and property. 

As detailed below, the requested exemption would permit the operation of a UAS under controlled 

conditions in the NAS that would be a) limited b) controlled c) and will provide safety enhancements to 

the already safe operations in the industry presently using conventional aircraft. Approval of this 

exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities to “....establish requirements for the safe operation of such aircraft 

systems in the national airspace system. 

 UAS to be Used 

TecNspecT, LLC will operate the Phantom 1 series of remote control model aircraft. Specifically the , 

the DJI Inspire 1. 

UAS Model Specifications 

Inspire 1 Yuneec Q500 4K

Weight (w/ Batt. And Props) 2935 g 1700 g

Diagonal Size (motor-motor 581 mm 565 mm

Max Ascent Speed 5 m/s 2m/s

Max Descent Speed 4 m/s 3m/s

Max Speed 22 m/s 13 m/s

Operating Temperature 0°C - 40°C 0°C -

Operating Freq. Band 2.4 GHz 2.4 GHz

Battery 4500 mAh 5400 mAh

Manufacturers Operating Manuals: 

Inspire 1 Manual 

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf

Yuneec Q500 4K

Yuneec.com/support/download/manuals/q500_4k_user_manual.pdf
National Security 

The small size of these UAS and the limited scale of operations in conjunction with adherence to the 

Reform Act’s safety requirements present no national security issues. 

Public Interest 

Services utilizing small UAS for aerial photography, videography, surveying, mapping, equipment 

inspections and auditing provides a much lower cost and higher level of safety to the public due to the 

small scale of aircraft relative to full scale aircraft operations. 

 Operational Safety 

 The UAS will not be operated at a speed exceeding 50 mph.

 The UAS will be operated at an altitude of no more than 400 feet above ground level (AGL).

 The UAS will be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC 

to be able to use human vision unaided by any device other than corrective lenses, as specified on the 

PIC’s FAA-issued airman medical certificate or U.S. driver’s license. 

 All operations must utilize a visual observer (VO). The UA must be operated within the visual line of 

sight (VLOS) of the PIC and VO at all times. 

 The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition

for safe operation. 

 Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a 

condition for safe flight. 

 PIC will hold either an airline transport, commercial, private, recreational, or sport pilot certificate.

The PIC will also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal Government. The 

PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the 

PIC is rated on his or her pilot certificate. 

 No operations will be conducted at night, as defined in 14 CFR § 1.1. All operations will be conducted

under visual meteorological conditions (VMC). 

 No operations will be conducted within 5 nautical miles of an airport reference point (ARP) as denoted 

in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of 

the airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of 

agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the 

exemption holder. 
 All operations shall be conducted over private or controlled-access property with permission from the 

property owner/controller or authorized representative. Permission from property owner/controller or 

authorized representative will be obtained for each flight to be conducted. 

 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance 

of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area 

associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets 

the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to 

exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated areas of the particular 

UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed will be at 

least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed. 

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, 

carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and 

designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled 

and monitored by both the operator and under the requirements and in compliance with local public 

safety requirements. These safety enhancements provide a greater degree of safety to the public and 

property owners than conventional operations conducted with airworthiness certificates issued under 

14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no 

credible threat to national security posed by the UAS, due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial 

external load. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires: When marks include only the Roman capital letter "N" and the registration 

number is displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to 

the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the 

words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. Even though 

the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no 

entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given 

the size of the UAS, two-inch lettering will be impossible. The word “Experimental” will be placed on the 

fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the UAS 

marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the 

UAS will see the identification of the UAS as “Experimental.” 

14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command. 

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in 

command of an aircraft that is carrying passengers or property for compensation or hire. V-Tail 
Aviation Inc. may achieve an equivalent level of safety as achieved by current Regulations because the 

applicant’s UAS do not carry any pilots or passengers nor property. The risks attendant to the operation 

of UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The PIC 

of the UAS will have a Commercial Pilot’s License along with a current Third Class or higher Medical 

exceeding the current safety levels in relation to 14 CFR 61.113 (a) & (b). I feel the operation and 

limitations set forth in the FOM will equate to the safe operation of the UAS. 

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for 

maintenance and use of safety check lists prior to each flight an equivalent level of safety will be 

provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides: No 

person may operate a U.S.-registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight 

Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current 

approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or 

any combination thereof. The UAS, given its size and configuration has no ability or place to carry such a 

flight manual on the aircraft, not only because there is no pilot on board, but because there is no room 

or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by 

keeping the flight manual at the ground control point where the pilot flying the UAS will have immediate 

access to it. 

14 C.F.R. § 91.103: Preflight Action. This regulation requires each pilot in command to take certain 

actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be 

provided for the aircraft an exemption will be needed. The PIC will take all actions as stated in the 

manufactures operating manuals. 

14 C.F.R. §91.109: Flight Instruction. 

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that 

is being used for flight instruction unless that aircraft has fully functioning dual controls. UAS and 

remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is 

accomplished through the use of a control box that communicates with the aircraft via radio 

communications. The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level 

of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by 

the small size and low speed of the aircraft. 

14 C.F.R. §91.119: Minimum Safe Altitudes. 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating the 

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption 

is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 

AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption 
may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 

400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a 

structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above 

the highest point on the structure. It will however be operated in a restricted area with security 

perimeter, where buildings and people will not be exposed to operations without their pre-obtained 

consent. The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well 

as the location where it is operated. No flight will be taken without the permission of the property 

owner or local officials. Because of the advance notice to the property owner and participants in any 

operational activity, all affected individuals will be aware of the planned flight operations. Compared to 

flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed 

herein and the lack of flammable fuel, any risk associated with these operations is far less than those 

presently presented with conventional aircraft operating at or below 500 AGL. In addition, the lowaltitude operations of the UAS will ensure separation between these UAS operations and the operations 

of conventional aircraft that must comply with Section 91.119. 

14 C.F.R. §91.121 Altimeter Settings. 

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to 

an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting 

available before departure.” As the UAS may not have a barometric altimeter, but instead a GPS altitude 

read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, 

pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch 

site shown on the GPS altitude indicator before flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR 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 

30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The battery powering the UAS 

provides approximately 30 minutes of powered flight. To meet the 30 minute reserve requirement in 14 

CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given the limitations 

on the UAS’s proposed flight area and the location of its proposed operations within a predetermined 

area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. Applicant 

believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating 

the UAS, in a tightly controlled area where only people and property owners or official representatives 

who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender 

the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small 

UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the 

exemption will be granted. Applicant believes that an equivalent level of safety can be achieved by 

limiting flights to 30 minutes or 25% of battery power— whichever happens first. This restriction would 

be more than adequate to return the UAS to its planned landing zone from anywhere in its limited 

operating area. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 
The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a 

civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate. 

. . . (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph 

(a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or 

cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs no more than 55 

lbs. and is operated without an onboard pilot. As such, there is no ability or place to carry certification 

and registration documents or to display them on the UAS. An equivalent level of safety will be achieved 

by keeping these documents at the ground control point where the pilot flying the UAS will have 

immediate access to them; to the extent they are applicable to the UAS. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. These regulations 

require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E 

of this part and shall between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or 

maintain the aircraft in compliance with Part 43. Given that these section and Part 43 apply only to

aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will 

be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent 

level of safety will be achieved because the UAS is very limited in size and will carry a small payload and 

operate only in restricted areas for a limited period of time. If mechanical issues arise the UAS can land 

immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the 

UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any 

maintenance performed. Moreover, 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. An 

equivalent level of safety will be achieved because maintenance and inspections will be performed in 

accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operator will ensure 

that the UAS is in working order prior to initiating flight and perform required maintenance needed. 

This application for exemption respectfully submitted by: 

TecNspecT, LLC 

1105 Meadow Bridge Lane

Arrington, TN 37014

615-943-0798 prichey0405@comcast.net 

Pat Richey

CEO