September 25, 2015

Exemption No. 1 3013 Regulatory Docket No. FAA

– 20 15

– 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 ai rcraft system (UAS) to

conduct aerial photography

.

See Appendix A for the petition submitted to the FAA des cribing 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, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of P ublic 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 the2

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

, C ertification procedures for products and parts, Subpart H

— Airworthin ess 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 collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 20 14

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , 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 peti tioner 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 i nterest.

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 g ranted 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 (part iculate measurement, etc.), or any other gathering of data by

instruments aboard the UA.3

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 Phanto m 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 film ing 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 maint ains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation fo r 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 thi s 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 and4

limita tions 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 ope rator 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 up dated 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 FA A’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 op eration 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 mu st 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 i s 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 comp onents, 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 Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certifi cate.5

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 (traini ng, p roficiency, 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 ma y only be conducted during dedicated training sessions. During

traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distanc e 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 symbo l 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 ma de 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 sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

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

20. The PIC is prohibited fro m 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 man ufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct

o perations that cannot be conducted under the terms of the attached COA

.6

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 nonpartici pating 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 r emain 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 control led

- access property with permission from the property owner/controller or aut horized 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 opera tional area as defined by the applicable COA must be reported

to the FA A'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

.7

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 Standa rds District Office (FSDO) with jurisdiction over the a rea 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 th e 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 certific ate 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 t o 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

essenti al 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 specifie d 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 91.8

This exemption terminates on October 31, 2017 , unless sooner superseded o r rescinded.

Sincerely,

/ s/

John S. Duncan Director, Flight Standards Service

EnclosuresMay 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

request ing 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 wit hin 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

o r wychetcoleman@gmail.com 1550 Airport Drive Shreveport, LA 71107

As d escribed 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 fulfill ing the Secretary of Transportation's (the FAA Administrator's) responsibilities to “.... establish requirements for the saf e 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 Re gulations 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 p revent Tubreaux Aviation Services, LLC, future commercial use of smallUASs 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

Servi ce s ' lightweight UASs meet the definition of "small unmanned aircraft" as defined in section 331 and therefore the integrati on of Tubreaux Aviation Service s ' lightweight UASs are expressly contem plated by the Reform Act. Tubreaux Aviation Services would

li ke 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 N ationa l Airspace S ystem (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 us ers of the NAS

, to the public

, or pose a thre at 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 o f 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 i n the N ational 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 horizon tal plane simultaneously. The UAS will operate only within the line of sight of the pilot within a protected flight area as

describ ed below. Such operations will e nsure that the UASs do not creat e a hazard to the users of the National Airspace S ystem or th e public.

The small nature of the UASs utilized by Tubreaux Aviation Services, LLC, com bined 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 all ow 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 m itigated 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, red uced 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 int erest. 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 purpo ses by Tubreaux Aviation Services, LLC :

1. Flights will be operated in the line

- of

- sight by a ground

- based pilot 2. Flight s 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 wil l be trained as to the applicable portion of

the UAS's manual as well as the SOPs.

7. Minimum UAS crew will be one certific ated 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 o perator 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 operat ions 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, clo sest 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 pe rsonnel as safety

observers.

10. Tubreaux Aviation Services, LLC, will employ s afety observers as well as sign notifications in areas close to pub lic 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. Tub reaux Aviation Services, LLC, will obtain cons ent (verbal or written) for any

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

13. Written and/ or verbal permission from th e relevant property owners will be obtained prior to flight.

14. All r equired permissi ons 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 it s 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: A irworthiness Certificates 14 C.F.R. 91.7(a), 91.203 (a)(1)

Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement ofnecessary 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 fro m 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 regis trations. 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 o perations center.

14 C.F.R. 91.7(a) prohibi ts 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 d istance 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 indi vidual 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 landin g, and assuming normal cruising speed

.

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

which is less than the reserve requirement alone by F ARs for day. Given the limitations on the UAS's flight envelope, proposed AOR size, battery life and its ability to land immediately it is reasona ble 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 gra nted 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 wor d "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 condition s. Tubr eaux Aviation Services, LLC, will only operate its UASs at or below 400 AGL. Tubreaux AviationServices, 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 op erations. 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 be low 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 r egulations 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

p rescribed in P art 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 gran ted. 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 priva te or cont rolled 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 r educing 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 Avia tion 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 aerialphotography. 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 a viation. 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, re spectfully 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