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 

"Extent ami reason for seeking relief' 

IsisCopter, LLC formally requests exemption from the above stated F ARs 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 of sight" operations; whichever comes first. The reason IsisCopter, 

LLC requests this relief is because my legitimate aerial photography business 

(EnviroSkyCam) is now defunct since hundreds of individuals with remote-control 

helicopters and multicopters equipped for aerial photo and video mission are offering 

their services at a fraction of the cost it takes me to operate my 1979 Beechcraft Bonanza 

A-36. The operating costs of owning and operating a piston-single are burdensome, and 

without the income to support these 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 F ARs from 

which I am legitimately seeking an exemption. 

As an FAA certified Commercial Pilot with multiengine and instrument ratings, my 

approach to 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 Beechcraft Baron B-58TC and also leased a Cessna C-421, 

both ofwhich were certified by my Principal Maintenance Inspector (PMI) and Avionics 

Inspector (AI). 
How tile request would benefit tlte public as a wltole ••• 

The experience of writing my own Statement of Compliance, Operations Manual and 

conducting all phases of a 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 of carrying passengers 

for hire. I conducted safe operations for several years; flying passengers as far south as 

Cabo San Lucas, as far north as Napa Valley, 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 that he asked me if I had any interest in working for the FAA. 

He told me "the pay is pretty good, benefits are great, and you 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 enjoyed running my own company. 

In addition to my 18 years of safely and continuously operating full-scale aircraft which 

varied in size from a Cessna 152 to a King Air-200 and a Premier Jet, I also have over 35 

years experience building and flying remote-control airplanes, helicopters, cars, boats, 

and most recently, multirotor aircraft. This unusual combination of experience places me 

in a position to educate others with less experience about the safe operation of remotely 

piloted UAS. Having personally tested hundreds, if not thousands of components for 

reliability and safety, I have a comprehensive database of parts that are either incorrectly 

manufactured and prone to failure, or poorly 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 of testing. My Naval 

Engineers and I build and fly multirotor platforms almost every day and we can provide a 

list of components and designs which are prone to failure and others which are reliable. 

Also, since my wife, Maha Tannous-Calderon, is a Commercial , multiengine, instrument 

rated pilot and a Certified Flight Instructor (License #2760176), she would assist in 

drafting training manuals for our business and could contribute our experience with other 

Public Agencies, educational facilities, etc. Finally, we plan to raise awareness ofthe 

public services UAS could provide so we are writing and producing a documentary titled 

"Civilian Drones." 
Reasons why the exemption would not adversely affect safety, or !tow tlze exemption 

would provide a level of safety at least equal to the existing rule 

Granting my Petition for an exemption would significantly increase public safety 

primarily because of the more than 35 years of testing 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 of parts 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 of our aerial platforms and only operate them 

within line-of sight (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 of our engineers (spotters). Additionally, the 

IsisCopter multirotor aerial platform is small and slow enough to adequately mitigate 

hazards to property and persons on the ground. IsisCopters utilized for commercial 

operations would never conduct autonomous flight operations. 

The vast majority of our aerial photo and video flights would occur at less than 100 AGL, 

which is often below the height of many trees, buildings, and obstacles so conflict with a 

full-scale aircraft or helicopter would be extremely improbable. Furthermore, if the FAA 

grants this petition, I would be the only "Pilot-In-Command" of any commercial flights. 

In addition, I have a comprehensive understanding of the 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 can publish in the Federal Register stating: 

The rule from which you seek the exemption 

A brief description of the exemption you seek 

IsisCopter, LLC formally requests exemption from the above stated FAR Title 14 CFR 

Part 21.191 & Part 91.319 for a period of24 months or until the UAS Integration Office 

officially amends the regulation prohibiting manually remote-controlled miniature 

aircraft from performing commercial photo and video "line of sight" operations; 

whichever comes first. A current FAA certified Commercial pilot with at least 35 years 

of experience in operating remote control miniature aircraft and 1 0 years experience in 

aerial photography using full-scale aircraft is seeking an exemption from the 

aforementioned F ARs. 
Any additional information, views, or arguments available to support your request 

Sadly, I had to place my successful "on-demand" air charter operation on hold after my 

parents fell gravely ill in 2003. Since my parents 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 of the flexibility it offered me. I 

quickly became successful with well-known clients like Sotheby's and exclusive brokers 

in Southern California. 

During the past few years, my aerial photography business began to decline rapidly. I 

realized that my customers were hiring individuals with remote control helicopters and 

digital cameras to conduct commercial flight operations for significant financial gain. 

Being an honest and ethical FAA Commercial Pilot, I refused to violate the F ARs like 

literally thousands of other people are currently doing. Even though I have been 

recreationally flying remote control airplanes since 1977, I have also done extensive 

research on r/c aerial photography and cinematography in the hopes that I would one day 

operate a business without violating the F ARs. 

According to the FAA AC 91-57 and the Academy of Model Aeronautics (AMA) 

guidelines, anyone can remotely pilot a gas-powered aircraft weighing up to 55 pounds 

and capable of speeds over 200 mph without any safoty training whatsoever. As long as 

they do not fly closer than 2 5 feet to any individual and remain below 400 foet when 

within 3 miles of an operating control tower and maintain visual contact of their aircraft! 

Recreational remote control pilots have an enormous amount of freedom which has 

resulted in numerous accidents and injuries, and even fatalities over the years. 

However, if a Commercial Pilot such as myself charges a Realtor $50 for flying a 2 

pound Styrofoam electric airplane with a 4 ounce digital camera strapped to the fuselage, 

it is a violation of the F ARs. This inconsistency must be addressed in order to protect the 

general public from the large number of illicit 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, San Diego Botanical Gardens, etc. We have been asked to use 

·our aerial platforms to educate the Pepperdine University Film School about aerial 

cinematography and they have offered compensation. We have declined this and other 

offers because of the current F ARs. 

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 of flight stabilizers, 

back-up systems, flight data downlink, etc. would bring a greater degree of safety to the 

amateur UAS community, which is growing at an alarming rate because of the low cost 

of entry. Additionally, because I have purchased and built over 125 miniature aircraft 
during 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 of thirsty young minds who cannot afford to train on real aircraft. 

These individuals are more likely to be motivated to learn rules and procedures when 

they have the satisfaction of maneuvering a small UAS. They will understand the basics 

of flight safety. There are hundreds of young minds in the Southern California area alone 

that would be thrilled at the prospect of learning 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 F AAST team representative. 

Together, we can close the generational gap and infuse the FAA with new life. Allow 

young people to indulge in the passion to fly. Involve and educate. Some will fly UAS 

regardless of the rules while others may not be aware of any rules. 

Education is essential for safe piloting ofUAS! 

Merging the creativity oftoday's youth with the experience of established pilots can 

result in great leaps for the FAA and a positive public image. We would like to 

eventually offer UAS training DVD's that explain the intricacy of airspace and the need 

for situational awareness and safety at all levels of aviation --whether manned or 

unmanned. 

If we are granted an exemption to 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 of the high cost of aerial filming. We strongly believe that once we succeed 

in our mission, we will pave the way for a generation of safe, knowledgeable and 

proficient UAV pilots with a rounded education and a careful approach. 

Innovation and ingenuity is the key to recovery of the U.S. Economy! 

IsisCopter was created to solve the problem of the high cost of aerial filming. We 

strongly believe that once we succeed in our mission, we will pave the way for a 

generation of safe, 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 create jobs in the US and stimulate our local economy. 

Once we are established, we hope to volunteer some of our time to assist the training of 

First Responders in the art of flying UAS. We strongly believe that Public Agencies such 

as fire departments and EMS can benefit from the many decades of hands-on experience 

of the lsisCopter team. 
Here is a brief description of the 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 of Science in Geology; University of Arizona 

Bachelor of Science in Geology; Boston College 

Laboratory Director for T.E.M. Analytics; Tucson, AZ 

Research Gemologist at the Gemological Institute of America; Santa Monica, CA 

Founder of EnviroSkyCam, 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 

Chief Auxiliary man on Nuclear Submarines, including Diving Officer. 

Nuclear Weapon Security Supervisor. Ship's Control Supervisor for all special weapons. 

Chief of the Watch, Sub-Safe Supervisor (QA Supervisor) for all Sub-Safe systems. 

Atmosphere Control Supervisor, also in charge of Oxygen systems. 

Damage Control Supervisor, responsible for ship and crew safety. 

Engine room Supervisor and Engineering Officer of the Watch on 692 Class Destroyers. 

Responsible for and to all standards including US Navy, and International Protocol. 

Maintenance Manager at Steris Isomedix plant. 

Responsible for commercial medical sterilization process (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 1985 
Irvin "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 at Naval 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; Computer research, Systems Manufacturing, Chip Design 

Automation for 25 years. 

Magma Design; Software Quality Assurance for 3 years 

Holds 3 U.S. Patents 

Author of several books about Microprocessors and Computers. 

San Diego State College Degree 

Started RC flying in the early 1960s, since the inception of the hobby. 

Kenneth "Ken" MacLeod 

MS in Electrical Engineering, with Computer Science. 

Stanford University, Honors, 1973 

BS in Electrical Engineering, with Computer Science. 

University of Pennsylvania, Highest honors, 1970 

BA in Liberal Arts, Ursinus College, High honors, 1969 

Director of Technology, Quad Research in Irvine, CA 

Director of Marketing, and Member of Board of Advisors: AmerNet Irvine, CA 

Director, Advisory Board of Directors, New Visual in San Diego, CA 

Director of Marketing, Valence Semiconductor in Irvine, CA 

Director, Product Planning, Standard Microsystems Corp in Irvine, 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 Southwest Texas State University, TX 

BA, Computer Science from University of Texas, 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 of America, Santa Monica, CA 

Editor and Staff Writer, 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 of remote 

control model airplanes and miniature UAS. 

Respectfully, 

Gus Calderon 

IsisCopter, LLC 

(760) 519-1941