rev.	4 					04-17-2015

TechJet, Inc.

9309 Sesh Road

Clarence Center, NY 14032

716.830.1021

usjetservice@aol.com

Inc.

TechJet, Inc.

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 request pursuant to Section 333 of the FAA Reform Act

 and specified parts under 14 CFR, the 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 CFR Part 11.81, TechJet, Inc., an “operator” of Unmanned Aircraft Systems (“UASs or 

UAS”) for aerial photography, hereby applies for an exemption from the Federal Aviation 

Regulations (“FARs”) to allow commercial operation of its UAS platforms in the National 

Airspace System (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

 Phone: 716-830-1021

 Address: 9309 Sesh Rd

 Clarence Center, NY 14032

 Email: usjetservice@aol.com

The operator, TechJet Inc., is owned and run by an experienced Airline Transport Pilot, 

Certificated Flight Instructor, director of flight operations, and current PIC qualified Part 135 

pilot. Furthermore, an additional employee is an experienced Airline Transport Pilot, current 

Certificated Flight Instructor, and current SIC qualified Past 135 pilot. Both have college degrees 

in aviation. They have the professionalism, the experience, the knowledge, the resources, and 

vested interests 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 Inc. 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 by TechJet, Inc. weigh less than 55 pounds, including all payload. They

operate at speeds of less than 50 knots, can hover, and can simultaneously move in multiple

1
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directions. TechJet, Inc. will only operate its UASs in line-of-sight (LOS) and with at least two 

FAA certificated pilot operators when applicable. Such operations will insure that the UAS will 

not create a hazard to users of the NAS and the general public.

The Unmanned Aircraft System

The UAS operated by TechJet, Inc. is a DJI S1000+ Octo-rotor 3-axis gimbal GPS positionaugmented 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 S1000+ has eight electric motors that are independently controlled by the craft. Safety 

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 

the UASs and the limited area in which they will operate, approval of this application presents no 

national safety concerns. Based on the substantial level of safety surrounding the proposed 

operations, and the significant public benefit (enhanced safety.) 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, Inc. respectfully 

requests that the FAA grant the requested exemption. 

Aircraft and Equivalent Level of Safety

The operating limitations proposed by TechJet, Inc. provide for a higher level of safety because 

UAS operations further enhance safety of aerial photography operations over using conventional 

aircraft. 

As set forth herein by TechJet, Inc., 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

 Maximum 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 by onboard GPS system

 Minimum crew for each operation will consist of the UAS pilot, the observer 

 and a camera operator

 A UAS pilot will be Pilot in Command (PIC)
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 A UAS pilot will be an FAA certificated airman with at least a Private Pilot’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 planned UAS operations prior to each flight

 All personnel performing duties within the boundaries of the safety 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 Flight Standards District 

 Office when applicable for the specified flight requiring a specific COA, above and 

 beyond 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 safety 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 days, before the proposed operations commence if

 operations require a specific COA when operations occur outside the blanket COA, 

 unless the specific COA does not require the additional notification

 The Pilot and Observer 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 be able to communicate by voice and 

 may augment verbal communication by electrical means because of ambient 

 noise levels if necessitated for safety and/or if deemed helpful to the safe 

 operation of the UAS, as determined by the PIC

 Written and/or oral permission from the relevant property owners will 

 be obtained. 

 All required permissions and permits will be obtained from territorial, 

 state, county, or city jurisdictions, including local law enforcement, fire, or 

 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 Security 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)
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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, 

propeller 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 Marks; 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, if unable to 

affix some kind of label with the vehicle’s registration number on it, other 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 

registration number as assigned by the FAA. A cross reference of said numbers will be 

documented by the operator and available in the operator’s private records.

14 C.F.R. 45.27: Location of marks; nonfixed-wing aircraft

Specifically, §45.27(a) states that 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, displaying any type 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 by the operator to ensure balance, mechanical motion, and radio/GPS signal 

reception is not hindered. As guidance, a typical ideal location 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 numbers on this type of UAS and 

make it visible as required 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.
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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 

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of 

safety of current operations by requiring the PIC operating the aircraft to have a Private Pilot’s 

certificate rather than a Commercial Pilot’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 conventional manned aircraft, a UAS is remotely 

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 safety exceeds that provided by a 

single individual holding a Commercial Pilot’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 private 

pilot as PIC exceeds the present level of safety sought by 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 pilot to preflight an aircraft before flight to insure the safety of 

flight. As FAA approved rotorcraft flight manuals will not be used, an exemption is requested. 

However, an equivalent level of safety 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 safety of flight by the operator from gained 

experience that supplements the UAS information manual. The PIC 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 IMSAFE and PAVE models 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 PIC 

receiving instruction and piloting the UAS craft.
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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 pertinent parts, that: 

“Except when necessary for takeoff or landing, no person may operate an aircraft below the 

following altitudes, (c): Over other than congested areas. An altitude of 500 feet above the 

surface, except over open water or sparsely populated areas. In those cases, the aircraft may not 

be operated closer than 500 feet to any person, vessel, or structure.” Because TechJet, Inc.

requests authority to operate at altitudes only up to 400 feet AGL, an exemption is needed to 

allow such operations. The UAS will never operate higher than 400 feet AGL. It will, however, 

be operated in a restricted area within a Security Perimeter, where buildings and people will not 

be exposed to operations without their pre-obtained consent. 

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

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

property owner(s) or local official(s), whichever is applicable. Because of the advance notice to 

the property owner(s) and/or participant(s) of the UAS activity, all affected individuals will be 

informed of the planned flight operations. Compared to the flight operations for manned aircraft 

and the lack of flammable fuel, any risk associated with the proposed UAS operations is far less 

than conventional aircraft operating at or below 500 feet AGL. 

In addition, the low-altitude operations of the UAS will ensure separation between a UAS and 

conventional aircraft, adding to the safety 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 by 

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 safety will be 

achieved by the operator, pursuant to a safety checklist, confirming the altitude of the launch site 

shown on the GPS altitude indicator before flight.

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

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

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly

to the first point of intended landing, and, assuming normal cruising speed, (1) During the day, to 

fly after that for at least 30 minutes...” 

The battery powering the TechJet, Inc. UAS provides approximately 20 minutes of powered 

flight. Operations would be impossible to conduct in order to meet the 30-minute reserve 

requirement in 14 CFR 91.151. Given the limitations on the UAS’s proposed flight area, its 

proposed flight time, and proposed operations within a predetermined location, 14 CFR 91.151 is 
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inapplicable. Furthermore, operating the UASs in a tightly controlled area where only people, 

property owners, and/or official representatives will be allowed, less than 30 minutes of reserve 

fuel does not endanger the type of risk that 91.151 was intended to address.

The owner/operator of TechJet Inc. affirms that safety can be achieved by 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 Certificates 

Section 91.203(a) prohibits, in pertinent parts, any 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 copy of the Aircraft Registration Application as 

 provided for in § 47.31(c). 

Section 91.203(b) prescribes, in pertinent parts, that no person may operate a civil aircraft unless 

the airworthiness certificate or a special flight authorization issued under § 91.715 is displayed at 

the cabin or cockpit entrance so that it is legible to passengers or crew. 

A UAS has no certificate nor does it have a cockpit door. TechJet, Inc. is requesting an 

exemption from 91.203 (a) and (b), and also 91.715.

14 C.F.R. 91.205 (b): Powered civil aircraft with standard 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 safety and information, 

transmitted telemetry will be sent to the PIC and displayed 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 supply to operate a transponder. 

Furthermore, operations offered by the blanket COA will occur below ATC radar coverage. To 

ensure an equivalent level of safety, 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 by 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.
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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 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to TechJet, Inc. operations. Maintenance and inspections will be 

accomplished by the operator. An equivalent level of safety will be achieved because the UASs 

are limited in size, will carry a small payload and operate only 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 design redundancies will allow the UAS to have two 

of eight non-adjacent motors fail and still be able to fly safely.

The operator will ensure that the UAS is in working order prior to flight, perform any required 

maintenance, and keep a log of any substantial, non-preventative maintenance performed. The 

operator is a person familiar with the UAS and capable to maintain it in an airworthy 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, Inc. 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 commercially operate a small unmanned vehicle UAS less than 55 pounds in aerial 

photography operations. These exemptions should allow for a UAS to safely operate in the NAS 

where conventional aircraft regulations would be inapplicable.

As established by the UAS exemptions already granted by the FAA, allowing commercial 

operations of UAS in the aerial photography industry will enhance safety by reducing risk. 

Conventional aerial photography operations, using varying types 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 varying types of aviation fuel. Such aircraft must also 

fly to and from the shoot location at speeds that can exceed 50 knots over non-Safety Perimeter 

areas. In contrast, a UAS weighing fewer than 55 pounds and powered by batteries eliminates 

virtually all of that risk, given the small size and lack of combustible fuel. The UAS is carried, 

and not flown, to a job site. In this regard, the UAS carries no passengers or crew and, therefore, 

will not expose them nor person and property on the ground to the risks associated with manned 

relocation flights. 
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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, close to the ground, and in a sterile environment. 

UASs also have far less impact on the environment compared to the conventional aerial 

photography practices it replaces. As a result, they are far safer than conventional operations 

conducted with aircraft including, but not limited to, turbine helicopters or small single-engine 

aircraft flying near the ground, property, 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 security) 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 rapidly 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 why TechJet, 

Inc. would be operating outside the United States. Therefore, TechJet, Inc. 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 aforementioned reasons.

If you have any questions or need any additional information, please contact the undersigned at 

716-830-1021 or usjetservice@aol.com.

Respectfully yours, 

Brian R. McArthur

Owner, CEO

TechJet, Inc.