Date: July 26, 2015

From: Alvin Jolivette

To: Federal Aviation Administration

Subject: REQUEST FOR ISSUANCE OF EXEMPTION UNDER TITLE 14 CFR, SECTION 333 TO TEROSAUR

Ref: (a) FAA Notice 8900.268 

(b) Title 14 CFR

To Whom it May Concern,

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

C.F.R. Part 11, Terosaur hereby applies for an exemption from the Federal Aviation Regulations identified 

below to allow for the commercial operation of the following small UAS previously approved in an FAA

333 exemption: 3D Robotics IRIS+, 3D Robotics X8+, 3D Robotics Aero-M, DJI Phantom 3, and DJI Inspire

for aerial data collection. We also request an exemption for the 3D Robotics Solo and 3D Robotics Aero 

for aerial data collection.

Terosaur requests that the FAA review this petition pursuant to its "summary grant" process as the FAA 

has already granted exemptions similar in all material respects to this petition for aerial data collection. 

See FAA Grant of Exception Nos. 11062, 11109, 11112, and 11213.

Terosaur is a California corporation that consults with private and public entities for building and property 

inspections, and for developing safer and more effective operations. Terosaur’s stakeholders range from

private owners and managers of large properties, to municipal governments managing public assets, to 

scientific research institutions. Our stakeholders are required to perform inspections and collect data that

requires their employees or contractors to perform work off the ground and with the risk of injury. We

have found that by using a small unmanned aircraft system “sUAS” with a high resolution camera 

mounted on it, often times we can accomplish the same inspection and data collection and alleviate the

need to put anyone in danger.

Terosaur shares Congress’s goal of getting sUAS flying commercially in the United States safely and 

soon. In the FAA Modernization and Reform Act of 2012, Congress directed the FAA “to safely 

accelerate the integration of civil unmanned aircraft systems into the national airspace system” and, 

under Section 333 of that law, gave the FAA power to grant innovators “expedited operational 

authorization” to do so. By this petition, Terosaur is seeking authorization to conduct sUAS operations

to improve safety.

Information Supporting this Petition as Specified in 14 C.F.R. §11.81

A. Mailing address and other contact information:

Terosaur

Attn: AJ Jolivette

2200 S. Fairview 

Santa Ana, CA 92704

844.483.7672 1@Terosaur.com
 

B. The specific section or sections of 14 C.F.R from which Terosaur seeks exemption.

1. 14 CFR Part 21, Subpart H: Airworthiness Certificates.

2. 14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

3. 14 CFR 45.23 Display of Marks; General and 45.29 Size of Marks.

4. 14 CFR 91.9 Civil Aircraft Flight Manual, Marking, and Placard Requirements.

5. 14 CFR 91.119 Minimum Safe Altitudes.

6. 14 CFR 91.121 Altimeter Settings.

7. 14 CFR 91.151 Fuel Requirements for Flight in VFR Conditions.

8. 14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Maintenance, and Alterations.

9. FAA Notice 8900.227 Paragraph 16(c) (4) PIC Medical and Paragraph 16(e)(1) Observer

Medical.

C. The extent of relief Terosaur seeks, and the reason Terosaur seeks the relief.

Terosaur seeks exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 91, and 

FAA Notice 8900.227 to the extent necessary to engage in commercial operations of a sUAS. If granted 

these exemptions we would operate the sUAS with the property owner’s written permission.

Terosaur’s intent is to use a sUAS for aerial data collection:

1. Aerial photography and video to support inspections of rooftops and structures, surveys of 

land and agriculture, support services for public entities, training and research.

2. Thermal and environmental information to support inspections, training and research.

We have safeguards that will apply to our proposed sUAS operations that will provide a level of safety 

meeting or exceeding the level of safety required of similar sUAS operations that the FAA authorizes

currently. In addition, our operations will not create a hazard to users of the national airspace system or

the public or pose a threat to national security and are thus consistent with the congressional mandate in 

Section 333 of the FAA modernization and Reform Act of 2012, which gives the FAA a mechanism to

allow certain UAS to operate safely in the national airspace system.

D. The reasons why granting Terosaur’s request would be in the public interest, and benefit the public

as a whole.

This would benefit the public by giving Terosaur a capable risk mitigated data collection platform.

The proposed sUAS gives Terosaur an alternative to sending humans into dangerous situations off the 

ground, and/or require that large or heavy equipment or apparatus be used in a populated areas to 

enable data collection. This in turn could prevent accidents and related deaths. 

Additionally, when Terosaur’s sUAS data collection flights are used as a substitute for data collection 

by manned helicopter or fixed wing aircraft, our use of a sUAS will reduce safety risks by not carrying 

flammable fuel, not carrying a pilot, and not requiring an object much greater than 55 pounds to be 

flying over populated areas. This could prevent accidents and related deaths. Another smaller point is 

that Terosaur’s sUAS utilizes electric energy in low quantities in comparison to a manned aircraft’s fossil 

fuel requirements during flight. There will be a reduced contribution to greenhouse emissions that 

contribute to climate change, and this contributes a small added benefit to the public.

The prevention of accidents and related deaths and injuries have a positive effect on those 

individual’s lives, their families, local communities and businesses, and the public as a whole.
 

E. The reasons why granting the exemption would not adversely affect safety, or how the exemption 

would provide a level of safety at least equal to that provided by the rule from which Terosaur seeks the

exemption.

Terosaus’s sUAS operations will provide a level of safety that exceeds the level of safety required 

by the FAA for hobbyists and manufacturers of model aircraft. The following operating procedures will 

apply during the sUAS inspection operations under this exemption request.

1. The sUAS that Terosaur has chosen to work with has an operational weights less than 7

pounds and will be powered via a battery source.

2. Terosaur inspection operations will be conducted:

i. within the visual line of sight of the Pilot in Command (PIC) and one or more Visual

Observers (VO).

ii. at less than 400 feet AGL

iii. within Class G airspace.

3. Terosaur’s data collection operations will be conducted in a confined area over private 

property located at least 5 miles away from any airport, heliport, seaplane base, spaceport

or other location with aviation activities, and any military or U.S. government installations

or airfields. If we are within the 5 mile radius of any of the above installations Terosaur will 

seek written approval from that installation’s owner before sUAS operations take place. If 

said installation owner requires stricter guidelines for operation then Terosaur will comply.

4. All sUAS operations will remain within the lateral and vertical boundaries of the operating 

area, taking into account all factors, including wind, gross weight, weather, and glide

distances that may affect the capability of the sUAS to remain within the airspace boundary;

moreover, the ceiling height will be no more than 400 feet AGL.

5. Terosaur sUAS operations under this exemption will be conducted under the supervision 

designated PIC who ultimately has final responsibility for the operation in accordance with 

14 C.F.R. 91.3.

6. PIC will maintain the sUAS system in a condition for safe operation, and conduct a pre‐flight 

inspection prior to each flight so as to ensure that the sUAS, control station, data link 

equipment, camera, and support equipment are in a condition for safe operation and in a 

configuration appropriate for the purpose of the intended flight.

7. The PIC and VO will maintain two‐way communications with each other during all 

operations; if unable to maintain two‐way communications, or if any condition occurs that 

may otherwise cause the operation to be unsafe, the operator will immediately conclude 

the operation.

8. Each sUAS that Terosaur will employ under this exemption will safely return automatically

to a home location designated by the PIC if the communications link is lost.

9. The aircraft documentation required by 14 C.F.R. §§ 91.9 and 91.203(b), as applicable, will 

be available to the PIC referred to above at any time Terosaur sUAS are operating.
 

F. A summary the FAA can publish in the Federal Register, stating: (1) The rule from which you seek 

the exemption; and (2) A brief description of the nature of the exemption you seek.

1. Petitioner: Terosaur

2. Sections of 14 C.F.R. Affected: §§ Part 21, Subpart H; 91.203; 45.23; 91.9; 91.119; 91.121;

91.151; Subpart E; and 8900.227 para(16)(4).

3. Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. §§

Part 21, Subpart H; 91.203; 45.23; 91.9; 91.119; 91.121; 91.151; Subpart E; and 8900.227 

para(16)(4)in order to conduct commercial small unmanned aircraft system operations on 

sites with owner approval subject to operating procedures that meet or exceed those that

FAA requires for similar operations.

G. If you want to exercise the privileges of your exemption outside of the United States, the reason 

why you need to do so.

Terosaur does not wish to exercise the privileges of this exemption outside of the United States at

this time.

Thank you for your consideration and I look forward to your response. I can be contacted directly 

via email or cell phone at your convenience.

Respectfully,

Alvin Jolivette

Alvin Jolivette

CEO / CTO

TEROSAUR

2200 S. Fairview 

Santa Ana, CA 92704

626.524.6224 aj@terosaur.com

844.483.7672 1@terosaur.com

www.terosaur.com