August 21st, 2012
Unmanned Aircraft Systems Integration Office, AJV-115 490 L'Enfant Plaza SW, Suite 3200 Washington, DC 20024 

### Petitioner: IsisCopter, LLC Gustave P. Calderon 878 Hollyhock Court Carlsbad, CA 92011 Tel: (760) 519-1941 E-mail: Jetcruise@earthlink.net 

### Comment Tracking#810e4655 Docket# FAA-2007-0001-0001

IsisCopter, LLC formally submits this Petition for Exemption from FAR Title 14 CFR Part 21.191 & Part 91.319 

### "Extentamireasonforseekingrelief' IsisCopter, LLC formally requests exemption from the above stated FARs for a period of 24 months or until the UAS Integration Office officially amends the regulation of prohibiting manually remote-controlled miniature aircraft from performing commercial photo and video "line ofsight" operations; whichever comes first. The reason IsisCopter, LLC requests this reliefis because my legitimate aerial photography business (EnviroSkyCam) is now defunct since hundreds ofindividuals with remote-control helicopters and multicopters equipped for aerial photo and video mission are offering their services at a fraction ofthe cost it takes me to operate my 1979 Beechcraft Bonanza A-36. The operating costs ofowning and operating a piston-single are burdensome, and without the income to supportthese costs, I will have to sell my aircraft in this depressed market and economy. The numerous companies performing these commercial services are doing so in plain sight and making substantial income while violating the FARs from which I am legitimately seeking an exemption.
As an FAA certified Commercial Pilot with multiengine and instrument ratings, my approachto air safety is a number one priority. I have been safely flying full-scale aircraft since July 1995 and have never received any violations or been involved in any incidents or accidents. Furthermore, in April2000, I was granted a single-pilot Part 135 Air Carrier Certificate #V8PA361J from the San Diego FSDO. My Principal Operations Inspector (POI) was Wayne F. Laner and I passed my oral and flight checks on the first attempt. I also passed my 135.299 (line check) & 135.297 (instrument proficiency) each and every time. At the time, I owned a BeechcraftBaron B-58TC and also leased a Cessna C-421, both ofwhichwere certified by my Principal Maintenance Inspector (PMI) and Avionics Inspector (AI).How tile request wouldbenefittltepublicas a wltole••• The experience ofwriting my own Statement ofCompliance, Operations Manual and conducting all phases ofa commercial Air Carrier Operation gave me extensive knowledge about conducting safe flight operations. In addition, I have gained invaluable experience about briefing passengers and the general public about flight safety. I fully understand that the FAA was required to monitor and observe all aspects of"Apogee Aviation" because I was granted the privilege and responsibility ofcarrying passengers for hire. I conducted safe operations for several years; flying passengers as far south as Cabo San Lucas, as far north as NapaValley, and as far east as Salt Lake City. My POI, Wayne Laner, was so impressed by my technical writing skills, record-keeping abilities and flight skills thathe asked me ifI had any interest inworking for the FAA. He told me "the pay is pretty good, benefits are great, andyou only have to work 4 days a week!" I was extremely flattered by the offer but, being an entrepreneur at heart, I politely declined because I enjoyedrunning my owncompany. In addition to my 18 years ofsafely and continuously operating full-scale aircraft which varied in size from a Cessna 152 to a King Air-200 and a PremierJet, I also have over 35 years experience building and flying remote-control airplanes, helicopters, cars, boats, and most recently, multirotor aircraft. This unusual combinationofexperience places me in a position to educate others with less experience about the safe operation ofremotely piloted UAS. Having personally tested hundreds, ifnot thousands ofcomponents for reliability and safety, I have a comprehensive database ofparts that are either incorrectly manufactured andprone to failure, orpoorly designed and may fail in flight and cause injury to the general public. The data I have is invaluable and I would be glad to share my findings with the FAA because I can save your organization years oftesting. My Naval Engineers and I build and fly multirotor platforms almost every day and we canprovide a list ofcomponents and designs which are prone to failure and others which are reliable. Also, since my wife, MahaTannous-Calderon, is a Commercial , multiengine, instrument rated pilot and a CertifiedFlight Instructor (License #2760176), she would assist in drafting training manuals for ourbusiness and could contribute our experience with other Public Agencies, educational facilities, etc. Finally, weplanto raise awareness ofthe public services UAS couldprovide so we are writing and producing a documentary titled "CivilianDrones."

### Reasons why the exemption wouldnotadversely affectsafety, or!tow 

### tlze exemption wouldprovide a levelof safety at leastequalto the existing rule Granting my Petition for an exemption would significantly increase public safety primarily because ofthe more than 35 years oftesting components from all countries around the world. Very few individuals have had the time, resources, and determination to acquire, test, and collect data on such a plethora ofparts from the remote control hobby industry as I have. Furthermore, my project manager, a retired Naval Engineer with 25 years ofRC piloting experience, has integrated back-up safety systems that allow for emergency operations such as "Return To Home" and "Position Hold." In addition, even though we always use manual control ofour aerial platforms and only operate them within line-ofsight (LOS) we still believe it is imperative to incorporate a live data downlink so we can monitor system voltage, current, altitude, and GPS coordinates at all times via a ground station monitored by one ofour engineers (spotters). Additionally, the IsisCopter multirotor aerial platform is small and slowenoughto adequately mitigate hazards to property and persons on the ground. IsisCopters utilized for commercial operations would never conduct autonomous flight operations.
The vast majority ofour aerial photo and video flights would occur at less than 100 AGL, which is often belowthe height ofmany trees, buildings, and obstacles so conflictwith a full-scale aircraft or helicopter would be extremely improbable. Furthermore, ifthe FAA grants this petition, I would be the only "Pilot-In-Command" ofany commercial flights. In addition, I have a comprehensive understanding ofthe National Airspace System and would only perform commercial operations in Class G Airspace during daytime Visual Meteorological Conditions. I would never fly any IsisCopter within close proximity of anyone and will have protective shrouds surrounding propellers or impellers.



### A summary we canpublish in the FederalRegisterstating: The rule from whichyouseekthe exemption A brief description of the exemptionyouseek IsisCopter, LLC formally requests exemption from the above stated FARTitle 14 CFR Part 21.191 & Part 91.319 for a period of24months oruntil the UAS Integration Office officially amends the regulation prohibiting manually remote-controlled miniature aircraft from performing commercial photo and video "line ofsight" operations; whichever comes first. A current FAA certified Commercial pilot with at least 35 years ofexperience in operating remote control miniature aircraft and 10 years experience in aerial photography using full-scale aircraft is seeking an exemption from the aforementioned FARs.

### Anyadditionalinformation, views, orargumentsavailable to supportyourrequest
Sadly, I hadto place my successful "on-demand" air charter operation onhold after my parents fell gravely 

### ill in 2003. Since myparents lived over 300 nautical miles away in Tucson, AZ, I had no choice but to terminate my business. I became involved in aerial photography and commercial photography because ofthe flexibility it offered me. I quickly became successful with well-known clients like Sotheby's and exclusive brokers in Southern California. During thepast few years, my aerial photography business beganto decline rapidly. I realized that my customers were hiring individuals with remote control helicopters and digital cameras to conductcommercial flight operations for significant financial gain. Being anhonest and ethical FAA Commercial Pilot, I refused to violate the FARs like literally thousands ofotherpeople are currently doing. Even though I have been recreationally flying remote control airplanes since 1977, I have also done extensive research onr/c aerial photography and cinematography inthe hopes that I would one day operate a business without violating the FARs. According to the FAA AC 91-57 and the Academy ofModel Aeronautics (AMA) guidelines, anyone can remotelypilotagas-poweredaircraftweighing upto 55pounds andcapable of speeds over 200mph withoutany safoty trainingwhatsoever. Aslong as they do not fly closer than 2 5 feet to any individualandremain below 400 foet when within 3 miles of an operatingcontroltower andmaintain visualcontactof theiraircraft! Recreational remote control pilots have an enormous amountoffreedom which has resulted in numerous accidents and injuries, and even fatalities overthe years. However, ifa Commercial Pilot such as myselfcharges a Realtor $50for flying a 2 pound Styrofoam electric airplane with a 4 ounce digital camera strappedto the fuselage, it is a violation ofthe FARs. This inconsistency mustbe addressed in orderto protectthe general public from the large number ofillicit commercial operations currently taking business away from legitimate aeril+l photography and cinematography operators. Isiscopter has performed charitable aerial photography missions for the Carlsbad Parks & Recreation Department, SanDiego Botanical Gardens, etc. We have been asked to use ·ouraerial platforms to educate the Pepperdine University Film School aboutaerial cinematography and they have offered compensation. Wehave declined this and other offers because ofthe currentFARs.
In my opinion, the AMA regulations are woefully lacking in safety training and do not address small UAS which are flooding the market. My knowledge offlight stabilizers, back-up systems, flight data downlink, etc. wouldbring a greater degree ofsafety to the amateurUAS community, which is growing at an alarming rate because ofthe low cost ofentry. Additionally, because I havepurchased and built over 125 miniature aircraftduring my lifetime, I have come to determine that some kits have faulty and unsafe parts. I would be glad to share this information with the FAA. Why educate?
There are thousands ofthirsty young minds who cannot afford to train onreal aircraft. These individuals are more likely to be motivated to learn rules and procedures when they have the satisfaction ofmaneuvering a small UAS. They will understand the basics offlight safety. There are hundreds ofyoung minds in the Southern California area alone that would be thrilled at the prospect oflearning to fly UAS. We can help harness that energy. My wife is a CFI who thoroughly enjoys interaction with students. She has donated her time and effort as a FAASTteam representative. Together, we can close the generational gap and infuse the FAA with new life. Allow young people to indulge inthe passionto fly. Involve and educate. Some will fly UAS regardless ofthe rules while others may not be aware ofany rules.
Education is essential for safe piloting ofUAS! Merging the creativity oftoday's youth withthe experience ofestablished pilots can result in great leaps for the FAA and apositivepublic image. We would like to eventually offer UAS training DVD's that explainthe intricacy ofairspace and the need for situational awareness and safety at all levels ofaviation --whether manned or unmanned.
Ifwe are granted an exemptionto perform commercial operations using remote control aerial platforms, we would be able to hire numerous employees and provide feedback to the FAA regarding flight training and safety protocols. IsisCopter was created to solve the problem ofthe high cost ofaerial filming. We strongly believe that once we succeed in ourmission, we will pave the way for a generation ofsafe, knowledgeable and proficient UAV pilots with a rounded education and a careful approach. Innovation and ingenuity is the key to recovery ofthe U.S. Economy! IsisCopter was created to solve the problem ofthe high cost ofaerial filming. We strongly believe that once we succeed in ourmission, we will pave the way for a generation ofsafe, knowledgeable and proficient UAS pilots with a rounded education and a serious approach to safety.

We are seeking out and teaming up with US manufacturers to create the safest UAS made in the United States. We hope to createjobs in the US and stimulate our local economy. Once we are established, we hope to volunteer some ofour time to assist the training of First Responders inthe art offlying UAS. We strongly believe that Public Agencies such as fire departments and EMS can benefit from the many decades ofhands-on experience ofthe lsisCopterteam.Here is a briefdescription ofthe highly qualified individuals involved in the IsisCopter project:

Gustave "Gus" Calderon
FAA Commercial License #167626407 Multiengine & Instrument Ratings Granted Part 135 Air Carrier Certificate #V8 PA361J
Master ofScience in Geology; University ofArizona Bachelor ofScience in Geology; Boston College Laboratory Director for T.E.M. Analytics; Tucson, AZ Research Gemologist at the Gemological Institute ofAmerica; Santa Monica, CA Founder ofEnviroSkyCam, an Aerial Photography business with BE-36; now defunct. Began building & flying remote control airplanes in 1977.
Charles "Ed" Kirk:
U.S. Navy, 20 years; Retired ChiefAuxiliary man on Nuclear Submarines, including Diving Officer. Nuclear Weapon Security Supervisor. Ship's Control Supervisor for all special weapons. Chiefofthe Watch, Sub-Safe Supervisor (QA Supervisor) for all Sub-Safe systems. Atmosphere Control Supervisor, also in charge ofOxygen systems. Damage Control Supervisor, responsible for ship and crew safety. Engine room Supervisor and Engineering Officer ofthe Watch on 692 Class Destroyers. Responsible for and to all standards including US Navy, and International Protocol.
Maintenance Manager at Steris Isomedixplant. Responsible for commercial medical sterilizationprocess (Ethylene Oxide) equipment. Understood and met all EPA, OSHA and FDA standards. Designed, installed, programmed and maintained automation control systems. Responsible for all personnel safety and environment safety standards
Assistant Professor, Palomar College, 20 years Heating, Air Conditioning and Refrigeration. Course coordinator and Head Instructor. Course content included OSHA and EPA safety standards. Began building & flying remote control helicopters in 1985Irvin "lrv" Stafford U.S.Navy 4 Years; Retired Stationed at U.S. Naval Avaition Missle Test Center, Pt. Mugu, CA for 2 years- Classified Stationed atNaval Air Station Miramar, San Diego, CA for 2 years- Classified
General Dynamics; Scientific Satellite Test Lab, San Diego, CA for 5 years - Classified Burroughs/Unisys/Cadence; Computerresearch, Systems Manufacturing, Chip Design Automation for 25 years. Magma Design; Software Quality Assurance for 3 years Holds 3 U.S. Patents Author ofseveral books about Microprocessors and Computers. San Diego State College Degree Started RC flying in the early1960s, since the inception ofthe hobby.

Kenneth "Ken" MacLeod

MS in Electrical Engineering, with ComputerScience. Stanford University,Honors, 1973 BS in Electrical Engineering,with ComputerScience. University ofPennsylvania, Highest honors, 1970 BA in Liberal Arts, Ursinus College, High honors, 1969 Director ofTechnology, Quad Research in Irvine, CA Director ofMarketing, and Member ofBoard ofAdvisors: AmerNet Irvine, CA Director, Advisory Board ofDirectors, NewVisual in SanDiego, CA Director ofMarketing, Valence SemiconductorinIrvine, CA Director,Product Planning, Standard Microsystems Corp inIrvine, CA Marketing Manager, Computer Systems Division, Toshiba America; Irvine, CA Senior Product Manager, Western Digital; Irvine, CA Engineering Manager,Hewlett Packard; Roseville, CA

### Maha Tannous-Calderon
FAA certified Commercial License Multiengine & Instrument Ratings Certified Flight Instructor, License 2761076; Pinnacle Aviation, Carlsbad, CA

BA,Journalism from SouthwestTexas State University,TX BA, Computer Science from University ofTexas,Arlington,TX AA, Business Administration, McLennan Community College, Waco,TX GG, Graduate Gemologist, GIA, Santa Monica, CA Air Force ROTC,Baylor University, Waco,TX Owner, Mahapix Studio; Commercial Photography, Digital Image Editing,Graphic Design Commercial Photographer, Gemological Institute ofAmerica, Santa Monica, CA Editor and StaffWriter, Harte Hanks News Service; Austin,TX

On behalf of our very talented, experienced, and safety conscience development team, I would like to thank you for taking the time to read and review this petition. I look forward to working with the FAA UAS Integration Office in order to increase the safety ofremote control model airplanes and miniature UAS. Respectfully,

Gus Calderon IsisCopter, LLC (760) 519-1941