rev.	4 04
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- 2015 TechJet, Inc. 9309 Sesh Road Clarence Center, NY 14032 716.830.1021 usjetservice@aol.com I nc . TechJet, I nc. 9309 Sesh Road Clarence Center, NY 14032 U. S. Department of Transportation, Docket Operations West Building Ground Floor , Room W12
- 140 1200 New Jersey

Avenue , SE Washington , DC 20590 Re: Exemption r equest p ursuant to Se ction 333 of the FAA Reform Act and specified parts un der 14 CFR , t he Federal Aviation Regulations Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CF R Part 11 .81 , TechJet, I nc., an “ operator ” of Unmanned Aircraft Sy stems (“UASs or UAS ”) for aerial p hotography , hereb y applies for an exemption from the Fed eral Aviation Regulations (“FARs”) to allow commercial operation of its UAS platforms in the National Airspace S ys tem (NAS)
. On or about April 09, 2015 the FAA granted exemptions to one hundred thirty
- seven UAS operators . It is in good faith that this exemption request will follow the same outline of the exemptions granted for the same general intents and purposes to commercially operate UASs. This application is submitted by :

Company : TechJet, Inc Owner /CEO : Brian R. McArthur Ph one: 716
- 830
- 1021 Address: 9309 Sesh Rd

Clarence Center, NY 14032 E mail : usjetservice@aol.com The operator, TechJet I

nc., is owned and run b y an experienced Airline Transport Pilot, Cert ificated Flight Instructor, director of flight operation s , and current PIC qualified Part 135 pilot . Furthermore, an additional employ ee is an experienced Airline Transport Pilot , current Certificated Flight Instructor , and current SIC qualified Past 135 p ilot . Both have college degrees in aviation. They

have the professionalism, the experience, the knowledge, the resources, and vested interest s in conducting and maintaining safe UAS operations , as well as concern of the public’s general welfare at large. It is the intention of TechJet I nc. to receive the appropriate operating exemptions in order to engage in civil commercial and/or contracted governmental UAS operations for compensation or hire. UASs operated b y TechJet, I nc. weigh less than 55 pounds, including all pay load. The y operate at speeds of less than 50 knots, can hover, and can simultaneousl y move in multiple

1rev.	4 04
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directions. TechJet, Inc. wil l only operate its UASs in line
- of
- sight (LOS) and with at least two FAA certif

icated pilot operators when applicable . Such operations will insure that the UAS will not cre ate a hazard to users of the NAS and the general public.

The Un manned A ircraft Sy stem The UAS operated b y TechJet, I nc. is a DJI S 1000 + O cto
- rotor 3

- axis gimbal GPS position
augmented craft. Safety

features include GPS “return to home” functions when and internal or external signal malfunction is detected. The pilot can also activate this “return to home” feature. The S 1000+ has eight electric motors that a re independently

controlled by

the craft. Safet y redundancies include the ability for the UAS to have up to two non
- adjacent motors fail and still allow the aircraft to be easily maneuverable to a safe area for landing. Additional UAS craft added to the fleet will be notified to the FAA, if able and applicable. Given the small size of our UASs and the restricted area that they will be operated, TechJet, Inc. UAS operations adhere to the Reform Act’s safety requirements. Additionally , due to the size of t he UASs and the limited area in which they will operate, approval of this application presents no national safet y concerns. Based on the substantial level of safet y surrounding the proposed operations, and the significant public benefit (enhanced safet y . ) Reduction in environmental impacts in the outdoor setting these UASs will operate leaving no trace of activity behind, the grant of the requested exemption is in the public interest. Accordingly , TechJet, I nc. respectfull y requests that the FAA grant the r equested exemption. Aircraft and Equivalent Level o f Safety The operating limitations proposed b y TechJet, I nc. provide for a higher level of safet y because UAS operations further enhance safet y of aerial photograph y operations over using conventional aircraft. As set forth herein by

TechJet, I nc. , the limitations and conditions include:

 The UASs will weigh less than 55 pounds  Flights will be operated within line of sight of a pilot and observer  Airport owners and/or local air traffic control facilities will be contacted and notified if operations within the designated distance from that airport, pursuant to any conditions of COAs issued for commercial UAS flight activities  M aximum flight time for each flight will be 30 minutes or at 25% of battery power reserve whichever comes first  Flights will be operated at an altitude of no more than 400 feet AGL as indicated b y onboard GPS sy stem  Minimum crew for ea ch operation will consist of the UAS pilot, the observer and a camera operator  A UAS pilot will be Pilot in Command (PI C )rev.	4 04
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- 2015 3

 A UAS pilot will be an FAA certificated airman with at least a Private P ilot’s certificate and at least a current third class Medical  An established “Security Perimeter” for the flight operations area  A briefing will be conducted for p lanned UAS operations prior to each flight  All personnel p erforming duties within the boundaries of the safet y perimeter are required to participate  The operator will file a FAA Form 7711
- 1 or its equivalent, as modified in light of the requested exemption, with the appropriate F light Standards Di strict Office when applicable for the specified flight requiring a specific COA, above and bey ond the blanket COA authorized by the FAA on March 23 , 2015, once such blanket COA is issued to this operator  The operator will attempt to verbally notify all persons involved in the filming and the operations , and ensure that they will stay no closer than the specified safet y distance (vertical and lateral) of the flight operation, when applicable  The operator will submit a written Plan of Activities to the FSDO at least 1 calendar day , including non
- business day s , before the proposed operations commence if operations require a specific COA when operations occur outside the blanket CO A , unless the specific COA does not require the additional notification  The Pilot and O bserver must be trained in UAS operations and received current information on the particular UAS to be operated  The Pilot and Observer will at all times b e able to communicate b y voice and may augment verbal communication by electrical means because of ambient noise levels if necessitated for safet y and/ or if deemed helpful to the safe operation of the UAS , as determined b y the PI C  Written and/or oral permission from the relevant propert y owners will be obtained.  All required permissions and permits will be obtained from territorial, state, county , or cit y j urisdictions, including local law enforcement, fire , o r other managing governmental agencies, if applicable  If the UAS loses communications or loses its GPS signal, the UAS will and does have the capability

to return to a pre - determined location within the Secu rity

Perimeter and land safely  The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies **Regulations from which the exemption is requested :**  **14 CFR 21 14 CFR 45.23(b)**  **14 CFR 45.27 14 CFR 45.29**  **14 CFR 61.113 (a) and (b) 14 CFR 91.9 (b) (2)**  **14 CFR 91.103 14 CFR 91.109**  **14 CFR 91.119 14**  **CFR 91.121**  **14 CFR 91.151 (a)**  **14 CFR 91.203 (a) and (b) 14 CFR 91.205 (b)**  **14 CFR 91.215 14 CFR 91.405 (a)**  **14 CFR 91.715 14 CFR 407 (a) (1)**  **14 CFR 409 (a) (2) 14 CFR 417 (a) and (b)** rev.	4 04
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Explanations of Requested Exemptions
14 C
. F
. R
. 21 : Certification Procedures for Products and Parts This regulation is designed for manned aircraft. It is not suitable for off
- the
- shelf or production UAS. All parts come from the manufacturer. Substantive replacement parts (i.e. motors, propelle r blades, radio transmitters, etc.) also come from the manufacturer or an authorized vendor with approved after
- market components and will ensure correct equipment is used to replace substantive parts of the UAS craft.
14 C
. F
. R
. 45.23(b) : Display of M arks; general Normally , a small decal or sticker label with non
- standard alphanumeric markings (as mentioned in 14 CFR 45.29) should be able to be affixed the UAS in some location. However, i f unable to affix some kind of label with the vehicle’s registration number on it , o ther identifiable numbers will be used from the craft, such as manufacturer’s serial number and/or a designated vehicle number from the operator, TechJet, Inc. that can be used to cross reference the UAS to the re gistration number as assigned b y the FAA. A cross reference of said numbers will be documented b y the operator and available in the operator’s private records.
14 C.F.R. 45.27 : Lo cation of marks; nonfixed
- wing aircraft Specificall y, § 45.27 (a) states tha t for Rotorcraft: Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by §45.23. Because this is neither a passenger rotorcraft nor contains a cabin , book, or tail in the traditional sense , display ing an y t yp e of registration marking cannot be accomplished
. Therefore, the next best location will be used to place the UAS aircraft registration number, This will be determined b y the operator to ensure balance, mechanical motion, and radio/GPS signal reception is not hindered. As guidance, a ty pical ideal locat ion may

be the booms for the motor arms or the landing gear assembly
. 14 C.F.R. 45.29: Size of Marks There will be insufficient space to display aircraft registration number s on this ty pe of UAS and make it visible as require d by this section
. A smaller decal or sticker label with non
- standard alphanumeric markings will be affixed to the UAS in some location in order to identify the craft
.rev.	4 04
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14 C.F.R. 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command Sections 61. 113 (a) and (b) limit private pilots to non
- commercial operations. Because the UAS w ill not carry

a pilot or passengers, the proposed operations can a chieve the equivalent level of s afet y of current operations by requiring the PI C op erating the aircraft to have a Private P ilot’s certificate rather than a Commercial P ilot’s certificate to operate a small UAS , even though civil commercial and/or contracted governmental UAS activities will receive monetary or other compensation for work performed . Unlike a con ventional manned aircraft, a UAS is remotel y controlled by

a ground
- based operator. The operational area is controlled and restricted, and all flights are planned and coordinated in advance. The level of safet y exceeds that provided by a single individual holding a Commercial P ilot’s certificate operating a conventional aircraft for hire. The risks associated with the use of a UAS are so diminished from the level of risk associated with commercial operations contemplated by part 61 allowing UAS use by a pri vate pilot as PI C exceeds the present level of safet y sought b y 14 C.F. R. 61.113 (a) and (b).
14 C.F.R. 91.9 : (b) (2) The need to have an aircraft manual onboard does not apply . UAS aircraft information manuals will be kept by

the operator. 14 C.F.R. 91.103: Prefight Action Section 91.103 requires each p ilot to preflight an aircraft before flight to insure the safet y of flight. As FAA approved rotorcraft flight manuals will not be used, an exemption is requested. However, an equivalent leve l of safet y will be provided using the manufacturer’s recommended preflight procedures per the supplied information manual with the UAS craft , as well as other necessary preflight steps deemed advantageous to the safet y of flight by the operator from gaine d experience that supplements the UAS information manual
. The PI C will take further actions, including reviewing weather, flight battery requirements, radio control communication checks and interference considerations, landing and takeoff distances , the flight environment , airspace considerations, and aircraft performance data before each flight. Other risk management tools, such as the IM SAFE and PAVE model s will be used a basis to determine flight readiness.
14 C.F.R. 91.109 : Flight instruction; Simulated instrument flight and certain flight tests At times, it will be necessary to certify and/or recertify other UAS operators in an instructional setting. There will be no persons onboard the UAS
. Also , on the ground, only a single UAS transceiver controller will be monitored by the person giving instruction to the current UAS PI C receiving instruction and piloting the UAS craft
.rev.	4 04
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14 C.F.R. 91.119 : Minimum Safe Altitudes Section 91. 119 establishes safe altitudes for operation of civil aircraft. Section 91.119 provides, in p ertinent part s , that: “Except when necessary

for takeoff or landing, no person may operate an aircraft be low the following altitudes, (c ): Over other than conges ted areas. An altitude of 500 feet above the surface, except over open water or sparsel y populated areas. In those cases, the aircraft may not be operated closer than 500 feet to an y person, vessel, or structure.” Because TechJet, Inc. requests authorit y t o operate at altitudes only up to 400 feet AGL, an exemption is needed to allow such operations. T he UAS will never operate higher than 400 feet AGL . I t will, however, be operated in a res tricted area within a Securit y P erimeter, where buildings and people will not be exposed to operations without their pre
- obtained consent. The equivalent level of safet y will be achieved given the size, weight, and speed of the UAS as well as the location where it is operated. No fligh t will be taken without th e permission of propert y owner(s) or local official ( s ), whichever is applicable . Because of the advance notice to the propert y owner(s) and/or participant(s) of the UAS activity , all affected individuals will be informed of the pl anned flight operations. Compared to the flight operations for manned aircraft and the lack of flammable fuel, an y risk associated with the proposed UAS operations is far less than conventional aircraft operating at or below 500 feet AGL. In addition, th e low
- altitude operations of the UAS will ensure separation between a UAS and conventional aircraft , adding to the safet y aspect of this exemption
. 14 C.F.R 91.121 Altimeter Settings Section 91.121 requires each person operating an aircraft to maintain cruising altitude b y reference to an altimeter that is set “... to an elevation of the departure airport or an appropriate altimeter setting available before departure.” As a UAS may not have a barometric altimeter, but instead a GPS altitude data, and an exemption is needed. An equivalent level of safet y will be achieved b y the operator, pursuant to a safety check list, confirming the altitude of the launch site shown on the GPS al titude 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 ) D uring the day , to fly after th at for at least 30 minutes.. .” The battery

powering the TechJet, I nc. UAS provides approximately 20 mi nutes of powered flight. Operations would be impossible t o conduct in order to meet the 30
- minute reserve re quirement in 14 CFR 91.151. Gi ven the limitations on the UAS’s proposed flight ar ea, its proposed flight time, and proposed operations within a pred etermined location, 14 CFR 91.151 isrev.	4 04
- 17
- 2015 7

inapplicable . Furthermore, operating the UASs in a tightl y controlled area where onl y people, propert y owners, and/ or official representatives will be allowed, less than 30 minutes of reserve fuel does not endanger the ty pe of risk that 91.151 was intended to address. The owner/operator of TechJet I nc. affirms that safet y can be achieved b y limiting flights to end with a 25% battery

reserve as indicated on the PIC’s controller mounted monitor. This restriction would be more than adequate to return the UAS to its predetermined landing area. 14 C.F.R. 91.203 (a) and (b), and 91.715 Airworthiness C ertificates Section 91.203(a) prohibits, in pertinent part s , an y person from operating a civil aircraft unless it has within it : (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. registration certificate issued to its owner or, for operation within the United States, the second cop y of the Aircraft Registration Application as provided for in § 47.31(c). Section 91.203(b) prescribes, in pertinent part s , that no person may operate a civil aircraft unless the airworthiness certificate or a special flight authorization issued under § 91.715 is display ed at the cabin or cockp it entrance so that it is legible to passengers or crew. A UAS has no certificate n or does it have a cockpit door. TechJet, I nc. is requesting an ex emption from 91.203 (a) and (b), and also 91.715. 14 C.F.R. 91.205 (b): Powered civil aircraft with stand ard category U.S. airworthiness certificates: Instrument and equipment requirements Section 91.205 pertains to cockpit instruments for manned aircraft occupied by at least one pilot. This is not applicable to UAS. However, to ensure an equivalent level of safet y and information, transmitted telemetry

will be sent to the PI C and display ed on a video screen indicating various parameters including, but not limited to, GPS altitude, GPS signal, battery power remaining, time in flight, UAS ground speed, etc.
14 C.F.R. 91.215: ATC transponder and altitude reporting equipment and use The UAS craft will have insufficient useful load and power suppl y to operate a transponder. Furthermore, operations offered b y the blanket COA will occur below A TC radar coverage. To ensure an equivalent level of safet y, when operations exist near a public airport, the operator will notify the local airport or ATC facility to advise them of the operation. If operations exist in an area not covered b y the blanket COA, then a specific COA for that operation will be obtained by the local FSDO and specific case
- by
- case coordination with ATC will be made for the UAS flight.rev.	4 04
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14 C.F.R. 91.405 (a) (1); 407 (a) (1); 409 (a) (2); 417 (a) and (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 sections and Part 43 appl y only to aircraft with an airworthiness certificate, these sections will not apply to TechJet, Inc. operations. Maintenance and inspections will be accomplished b y the operator. An equivalent level of safet y will be achieved because the UASs are limited in size, will carry a small pay load and operate onl y in restricted areas for limited periods of time. If mechanical issues arise, the UAS can land immediately and will be operating from no higher than 400 feet AGL. Specific d esign redundan cies will allow the UAS to have two of eight non
- adjacent motors fail and still be able to fly safel y . The operator will ensure that the UAS is in working order prior to flight, perform an y required maintenance, and keep a log of an y substantial, non
- preventative ma intenance performed. T he operator is a person familiar with the UAS and capable to maintain it in an airwo rthy condition.

**Summary for Publication** Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: TechJet, I nc. seeks an exemption from the following rules: 14 CFR: §§ **21; 45.23(b); 45.27; 45.29; 61.113 (a) and (b); 91.9 (b) (2) ;**  **91.103 ; 91.109;** 

**91.119; 91.121; 91.151 (a)**  **; 91.203 (a) and (b)**  **; 91.205 (b)**  **; 91.215**  **; 91.405**  **(a) ; 91.715; 407 (a) (1); 409 (a) (2);**  **417 (a) and (b)**

... to commerciall y operate a small unmanned vehicle UAS less than 55 pounds in aerial photograph y operations. These exemptions should allow for a UAS to safely operate in the NAS where conventional aircraft regulations would be inapplicable. As established b y the UAS exemptions already granted by the FAA, allowi ng commercial operations of UAS in the aerial photograph y industry will enhance safet y by reducing risk. Conventiona l aerial photograph y operations, using varying ty pes of conventional aircraft, operate at low altitudes and present the risks associated with aircraft that weigh at least 2 ,000 pounds and upward , and which carry

large amounts of vary ing ty pes of aviation f

uel. Such aircraft must also fly to and from the shoot location at speeds that can exceed 50 knots over non
- Safet y Perimeter areas. In contrast, a UAS weighing fewer than 55 pounds and powered b y batteries eliminates virtually all of that risk , given the s ma ll size and lack of combustible fuel. The UAS is carried, and not flown, to a job site . I n this regard , the UAS carries no passengers or crew and, therefore, will not expose them nor person and propert y on the ground to the risks associated with manned relocation flights.rev.	4 04
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The operation of UASs conducted in the strict conditions outlined within this exemption request provide at least an equivalent level of safety supporting the grant of the exemption requested herein. The UASs operate at slow speeds, cl ose to the ground, an d in a sterile environment. UAS s also have far less impact on the environment compared to the conventional aerial photograph y practices it replaces. As a result, they are far safer than conventional operations conducted with aircraft i ncluding, but not limited to, turbine helicopters or small single
- engine aircraft fl yi ng near the ground , propert y, and people. Satisfaction of the criteria provided in Section 333 of the FAA Modernization and Reform Act of 2012 (size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national securit y) provide more than adequate justification to grant TechJet, Inc. requested exemption, allowing for TechJet, Inc. UAS commercial operations. Any future requirements issued by the FAA pertaining to operating UASs commercially (e.g. written test, logging flight time experience, etc.) will be complied with as it is understood this is a rapid ly evolving sector of the aerospace industry with little regulatory affirmations as of yet. Additionally , because of the geographic location of the operator, TechJet, Inc, it may be necessary to conducted business and commercial UAS operations in and/or over the country of Canada. Particularly , the natural wonder and tourist attraction of Niagara Falls and businesses with real estate in and near the city Niagara Falls, Ontario are examples of reasons wh y TechJet, In c. would be operating outside the United States. Therefore, TechJet, I nc. finishes this exemption request with the consideration of 14 CFR 11.81 (h), allowing for commercial UAS operations with the need to “exercise the privileges of our exemption outside the United States” with the aforemention ed reasons.

If you have an y questions or need an y additional information, please contact the undersigned at 716
- 830
- 1021 or usjetservice@aol.com
. Respectfully yours ,

Brian R. McArthur Owner , CEO TechJet, I nc.