September 25, 2015

Exemption No. 13013

Regulatory Docket No. FAA–2015–2269

Mr. Travis Pierrelee

Tubreaux Aviation Services, LLC

1550 Airport Drive

Shreveport, LA 71107

Dear Mr. Pierrelee:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated May 8, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Tubreaux Aviation Services, LLC (hereinafter petitioner or operator) for an 

exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct aerial photography.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 3 Professional.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 
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aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Tubreaux Aviation Services, LLC is granted an 

exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 

91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform 

aerial data collection. This exemption is subject to the conditions and limitations listed 

below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, Tubreaux Aviation Services, LLC is hereafter referred to as 

the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3 

Professional when weighing less than 55 pounds including payload. Proposed 

operations of any other aircraft will require a new petition or a petition to amend this 

exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must 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.

6. 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 VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 
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limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. 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 UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must 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.
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14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate 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. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
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22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. 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.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.
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If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on October 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
May 8, 2015

United States Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act of 2012

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform 

Act) and C.F.R. Part 11, Tubreaux Aviation Services, LLC. owner and operator of Flight 

School, Aircraft Maintenance and Small Unmanned Aircraft Systems (UASs), is 

requesting to be exempted from the Federal Aviation Regulations (FARs) listed below so 

Tubreaux Aviation Services, LLC. may operate UASs commercially in airspace regulated 

by the Federal Aviation Administration; as 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.

The Name and address of the applicant is:

Tubreaux Aviation Services, LLC 

Attn: Travis Pierrelee - tpierrelee@suddenlink.net, 318.458.8946

 or wychetcoleman@gmail.com 

1550 Airport Drive

Shreveport, LA 71107

As described below, the requested exemption would permit the operation of lightweight 

(less than fifty five pounds (55 lbs.) total take off gross weight) UASs under controlled 

conditions for commercial use by professional certificated pilots thereby enhancing safety 

and fulfilling 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." Section 333(c) of the Reform Act.

Tubreaux Aviation Services, LLC. respectfully requests the grant of an exemption to the 

following specific sections of the Title 14 Code of federal Regulations allowing it to 

operate lightweight UAS's for commercial use:

14 CFR 21, subpart H, 14 CFR 45.23(b), 14 CFR 91.7(a), 91.9 (b)(2),

91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) &(b), 91.405(a),

91.407(a)(1), 91.409(a)(2), 91.417(a) &(b)

Tubreaux Aviation Services, LLC, submits this application in accordance with the 

Reform Act, 112 P.L. 95 331-334, seeking relief from any currently applicable FAR's

operating to prevent Tubreaux Aviation Services, LLC, future commercial use of small
UASs to operate in the national airspace system as described below. The Reform Act

Section 332 provides for such integration of civil unmanned aircraft systems into our 

national airspace system as it is in the public's interest to do so. Tubreaux Aviation 

Services' lightweight UASs meet the definition of "small unmanned aircraft" as defined 

in section 331 and therefore the integration of Tubreaux Aviation Services' lightweight 

UASs are expressly contemplated by the Reform Act. Tubreaux Aviation Services would 

like to operate its lightweight UASs prior to the time period by which the Reform Act 

requires the FAA to promulgate rules governing such aircraft.

The Reform Act directs the Secretary of Transportation to consider whether certain

unmanned aircraft systems may operate safely in the National Airspace System (NAS) 

before completion of the rulemaking required under Section 332 of the Reform Act. In 

making this determination, the Secretary is required to determine which types of UASs 

do not create a hazard to users of the NAS, to the public, or pose a threat to national 

security in regards to the following:

• The UAS's size, weight, speed and operational capability

• Operation of the UAS in close proximity to airports and populated areas

• Operation of the UAS within visual line of sight of the operator Reform Act 333 (a)

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.

Tubreaux Aviation Services, LLC UAS’s are rotorcraft weighing less than 55 pounds

including payload. They operate at a speed of less than fifty knots (50 knots) and have the

capability to hover and move in the vertical and horizontal plane simultaneously. The 

UAS will operate only within the line of sight of the pilot within a protected flight area as 

described below. Such operations will ensure that the UASs do not create a hazard to the 

users of the National Airspace System or the public.

The small nature of the UASs utilized by Tubreaux Aviation Services, LLC, combined 

with the safety protocols outlined below will allow for a greater than equivalent level of 

safety in which Congress envisioned that the FAA must, by exemption allow commercial 

operations of UASs to commence immediately. Also due to the size of the UASs and the 

areas and altitudes they will operate, approval of the exemption presents no national 

security issue and absolutely minimal safety concerns which have been mitigated through 

a rigorous risk management process. Given the clear direction given in Section 333 of the 

Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong 

equivalent level of safety surrounding the proposed operations, the significant public 

benefit, including enhanced safety, reduced emissions utilizing UASs verse traditional 

aircraft as well as the economic impact of greatly reducing the cost of aerial photography 

thereby benefiting the greater public's interest. Accordingly, the applicant requests that 

the FAA grant the requested exemption without delay.
The following limitations are considered to be binding for the operation of UASs for 

commercial purposes by Tubreaux Aviation Services, LLC:

1. Flights will be operated in the line-of-sight by a ground-based pilot

2. Flights will operate clear of clouds

3. The UASs will weigh less than 55lbs at take off and during flight

4. Flights will be terminated with 25% of battery life remaining

5. Flights will be operated at an altitude at or below 400' AGL

6. Pilots, camera operators and observers will be trained as to the applicable portion of 

the UAS's manual as well as the SOPs.

7. Minimum UAS crew will be one certificated Commercial pilot or higher rating with a 

current Second Class FAA medical certificate. A camera operator and/or observer may be 

added as required to further reduce the possibility of task saturation by the pilot 

depending on the mission requirements.

8. Pilot, observer and camera operator will maintain real time communication capability 

throughout flight operations.

9. The UAS Pilot will conduct a full site survey to determine the Area of Responsibility 

(AOR). This AOR is the actual area for UAS operations for a particular day. Each survey 

will include the assessment of potential hazards to include but not limited to airspace 

classification, NOTAMS, temporary flight restrictions, closest airport proximity, natural 

and manmade obstacles, and unnecessary persons which may pose a risk to operations or 

safety. If deemed necessary, the crew will employ additional personnel as safety 

observers.

10. Tubreaux Aviation Services, LLC, will employ safety observers as well as sign 

notifications in areas close to public activity.

11. A thorough briefing will be conducted, prior to the first flight of the day in an AOR, 

utilizing the briefing guide in the SOPs. All persons who will be in the AOR while UAS 

flights are conducted will be present for this briefing.

12. Tubreaux Aviation Services, LLC, will obtain consent (verbal or written) for any 

persons who need to be within one hundred 100 feet of UAS flight operations.

13. Written and/or verbal permission from the relevant property owners will be obtained 

prior to flight.

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

parish or city jurisdictions, including local law enforcement, fire or other governing 

governmental agencies.

15. If the UAS loses communications or loses its GPS signal, the UAS will have the 

capability to return to a pre-determined location within the AOR and land autonomously.

16. The UAS will have the ability to abort a flight in case of unpredicted obstacles or 

emergencies.

14 C.F.R Part 21 Subpart H: Airworthiness Certificates 14 C.F.R. 91.7(a), 91.203

(a)(1)

Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of 
necessary airworthiness certificates in relation to FAR 91.203(a)(1) The size, weight and 

defined area of operations for Tubreaux Aviation Services, LLC. UAS flights permits 

exemption from Part 21 because Tubreaux Aviation Services, LLC. meets an equivalent 

level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to 

exempt aircraft from the airworthiness certificate requirement under both the ACT (49 

U.S. C. 44701(f)) and Section 333 of the Reform Act. Both pieces of legislation permit 

the FAA to exempt UASs from the airworthiness certificate requirement in consideration 

of weight, size, speed, maneuverability and proximity to areas such as airports and dense 

populations. Tubreaux Aviation Services, LLC, meets or exceeds each of these elements.

14 C.F.R. 91.203 (a &b) provides for carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons stated above. The equivalent 

level of safety will be achieved by maintaining such certifications and registrations at 

Tubreaux Aviation Services, LLC flight operations center.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by the 

FARs, this regulation is inapplicable.

14 C.F.R. 91.9(b)(2) Civil Aircraft Flight Manual in the Aircraft

14 C.F.R. 91.9(b)(2) requires an aircraft flight manual in the aircraft. As there are no 

pilots or passengers, and given the size of the UASs, this regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining an operators manual at the 

flight operations center. The FAA has previously issued exemptions to this regulation in 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602,

10700 and 32827.

14 C.F.R. 91.103(b) Preflight actions

14 C.F.R. 91.103 Each pilot in command shall, before beginning a flight, become 

familiar with all available information concerning that flight. This information must 

include: (b) For any flight, runway lengths at airports of intended use, and the following 

takeoff and landing distance information. This subparagraph is not applicable due to our 

off airfield operations.

14 C.F.R. 91.109 Flight instructions; Simulated instrument flight and certain flight 

tests.

14 C.F.R. 91.109 and all the subparagraphs address the operation of a civil manned 

aircraft in conjunction with training and flight tests. The UAS to be employed by 

Tubreaux Aviation Services, LLC, are not designated in this category.
14 C.F.R. 91.121 Altimeter Settings

14 C.F.R. 91.121 regarding altimeter settings is inapplicable because Tubreaux Aviation 

Services, LLC, UASs utilize GPS systems and internal gyroscopes to provide spatial 

stability and a reference datum.

14 C.F.R. 91.151 Fuel Requirements for Flight in VFR Conditions

14 C.F.R. 91.151 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.

The battery powering the UAS provides approximately 15 minutes of powered flight, 

which is less than the reserve requirement alone by FARs for day. Given the limitations 

on the UAS's flight envelope, proposed AOR size, battery life and its ability to land 

immediately it is reasonable to allow an exception.

An equivalent level of safety can be achieved by limiting flights to 25% of battery power. 

This restriction would be more than adequate to return the UAS to its planned landing 

zone in the AOR.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 

5745, 10673 and 10808.

14 C.F.R. 45.23 Marking of the Aircraft

Applicable Codes of Federal regulations require aircraft to be marked according to 

certain specifications. Tubreaux Aviation Services UASs are (in fact) unmanned; do not 

have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, 

two-inch lettering is impractical to place on such small aircraft. Tubreaux Aviation 

Services, LLC, will, however, place the word "EXPERIMENTAL" on its fuselage as 

required by 14 C.F.R. 45.29 (f) so that the pilot, camera operator, observer and any other 

persons operating in the AOR can see the markings on the UAS. The FAA has previously 

issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167 A, 

and 10700.

14 C.F.R. 91.119 Minimum Safe Altitudes

14 C.F.R. 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. Tubreaux Aviation 

Services, LLC, will only operate its UASs at or below 400 AGL. Tubreaux Aviation 
Services, LLC, will operate its UASs in a defined AOR that has been carefully reviewed 

for hazards and minimizes the presence of any persons not essential for operations. 

Flights will only be conducted over private property with consent of the property owner. 

The 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. Compared to flight operations with

traditional aircraft or rotorcraft weighing far more than 55lbs, operating below 500 AGL 

with flammable fuel UAS operations present a far smaller risk.

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 the aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections, 

except as prescribed 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.

These regulations only apply to aircraft with an airworthiness certificate. They will not, 

therefore, apply to Tubreaux Aviation Services, LLC, UASs should its requested 

exemption be granted. As an equivalent level of safety, Tubreaux Aviation Services, LLC,

requires its pilots to conduct a preflight, thorough flight and post flight inspection of the 

UAS to ensure its flight worthiness prior to launch. Each UAS is flown in compliance 

with the applicable manufacturer’s manual to include all software update cycles as well 

as flight checklists. In the event of a malfunction the UAS can land immediately.

Privacy

All flights will occur over private or controlled access property with the property owner's 

prior consent and knowledge.

Summary

Tubreaux Aviation Services, LLC, is seeking exemption from the following rules: 

14 CFR 21, subpart H, 14 CFR 45.23(b), 14 CFR 91.7(a), 91.9 (b)(2), 91.103(b), 91.109,

91.119, 91.121, 91.151(a), 91.203(a)&(b), 91.405(a), 91.407(a)(1), 91.409(a)(2),

91.417(a)&(b).

Approval of the above exemptions allowing commercial operations of small UASs in the 

service of aerial photography will greatly enhance safety by reducing the overall risk 

associated with traditional aircraft. Traditional aerial photography requires large aircraft 

weighing thousands of pounds and carrying hundreds of pound of fuel presenting a 

significant risk to life and property. With Tubreaux Aviation Services, LLC’s use of 

small UASs weighing less than 55 lbs, powered by batteries and operating at or below 

400 AGL they virtually eliminate all of the risk associated with traditional aerial 
photography. The UASs will carry no people, thereby eliminating the exposure to the 

risks associated with flying while accomplishing the same task in a much safer manner.

Granting Tubreaux Aviation Services, LLC, the above exemptions will allow for the

expansion of UAS systems into the future, in a professional, safety conscious culture

steep in the tradition of aviation. The safety culture established by the founding members 

of Tubreaux Aviation Services, LLC, is based on our six (6) years of business experience. 

Tubreaux Aviation Services, LLC, respectfully requests that the FAA grant its exception 

without delay. The FAA has the authority to issue the exemption sought by Tubreaux 

Aviation Services, LLC pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as 

amended (the "Act").

Sincerely,

Travis Pierrelee

Tubreaux Aviation Services, LLC.

Shreveport, LA 

tpierrelee@suddenlink.net

wychetcoleman@gmail.com

318.458.8946 - Travis Pierrelee