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Chad	Copeland

CopelandRED	LLC

Cell:	+1.425.301.2110

chad.copeland@me.com

March	26,	2015

Shell	Docket	FAA-2007-0001

U.S.	Department	of	Transportation,	Docket Operations

West	Building	Ground	Floor,	Room	w12-140

1200	New	Jersey	Avenue,	SE	

Washington,	DC	20590

To	Whom	It	May	Concern:

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	and	

14	C.F.R.	Part	11,	CopelandRED	LLC,	research	and	developer	and	operator	of	Small	

Unmanned	Aircraft	Systems	equipped	to	conduct	aerial	photography	for	the	use	in	

public	periodicals	(ie:	National	Geographic,	Outside	Magazine),	motion	picture	and	

television	industry	for	controlled	and	closed	set	filming,	hereby	applies	for	an	exemption	

for	the	listed	Federal	Aviation	Regulations	to	allow	commercial	operation	of	its	UAS’s,	so	

long	as	such	operations	are	conducted	within	and	under	the	conditions	outlined	herein	

or	as	may	be	established	by	the	FAA	as	required	by	Section	333.

As	described	more	fully	below,	the	requested	exemption	would permit	the	

operation	of	small	UAS	under	controlled	conditions	in	airspace	that	is	1)	limited	2)	

predetermined	3)	controlled	as	to	access	and	4)	would	provide	safety	enhancements	to	

the	already	safe	operations	in	the	film	and	television	industry	presently	using	

conventional	aircraft.	Approval	of	this	exemption	would	thereby	enhance	safety	and	

fulfill	the	FAA	Administrator’s	responsibilities	to	“establish	requirements	for	the	safe	

operation	of	such	aircraft	systems	in	the	NAS.”	Section 333(c)	of	the	Reform	Act.

The	name	and	address	of	the	applicant	is:

CopelandRED	LLC

Attn:	Chad	CopelandRED	

Ph:	425.301.2110

Email:	chad.copeland@me.com

Address:	1808	40th Ave	E,	Seattle,	WA	98112
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Regulations	from	which	the	exemption	is	requested:	

14	CFR	Part	21, 14	C.F.R.	45.23(b), 14	CFR	61.113	(a)	&	(b), 14	C.F.R.	91.7	(a), 14	CFR	91.9	

(b)	(2), 14	C.F.R.	91.103, 14	C.F.R.	91.109, 14	C.F.	R.	91.119, 14	C.F.R.	91.121, 14	CFR	

91.151	(a), 14	CFR	91.203	(a)	&	(b), 14	CFR	91.405	(a), 14	CFR	407	(a)	(1), 14	CFR	409	(a)	

(2), 14	CFR	417	(a)	&	(b)	

This	exemption	application	is	expressly	submitted	to	fulfill	Congress’	goal	in	passing	

Section	333(a)	through	(c)	of	the	Reform	Act.	This	law	directs	the	Secretary	of	

Transportation	to	consider	whether	certain	unmanned	aircraft	systems	may	operate	

safely	in	the	national	airspace	system	(NAS)	before	completion	of	the	rulemaking	

required	under	Section	332	of	the	Reform	Act.	In	making	this	determination,	the	

Secretary	is	required	to	determine	which	types	of	UASs	do	not	create	a	hazard	to	users	

of	the	NAS	or	the	public	or	pose	a	threat	to	national	security	in	light	of	the	following:	

• The	UAS’s	size,	weight,	speed,	and	operational	capability;	

• Operation	of	the	UAS	in	close	proximity	to	airports	and	populated	areas;	and	

• Operation	of	the	UAS	within	visual	line	of	sight	of	the	operator.	

Reform	Act	§	333	(a).	Lastly,	if	the	Secretary	determines	that	such	vehicles	“may	

operate	safely	in	the	national	airspace	system,	the	Secretary	shall	establish	

requirements	for	the	safe	operation	of	such	aircraft	in	the	national	airspace	system.”	Id.	

§	333(c)	(emphasis	added).	

The	Federal	Aviation	Act	expressly	grants	the	FAA	the	authority	to	issue	

exemptions.	This	statutory	authority	by	its	terms	includes	exempting	civil	aircraft,	as	the	

term	is	defined	under	§40101	of	the	Act that	includes	UASs,	from	the	requirement	that	

all	civil	aircraft	must	have	a	current	airworthiness	certificate.	

CopelandRED	LLC’s UASs	are	rotorcraft,	weighting	55	or	fewer	lbs.	including	

payload.	They	operate,	under	normal	conditions	at	a	speed	of	no	more	than	87 knots	

and	have	the	capability	to	hover,	and	move	in	the	vertical	and	horizontal	plane	

simultaneously.	Such	operations	will	insure	that	the	UAS	will	“not	create	a	hazard	to	

users	of	the	national	airspace	system	or	the	public.”
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Given	the	small	size	of	the	UASs	involved	and	the	restricted	sterile	environment	

within	which	they	will	operate,	the	applicant	falls	squarely within	that	zone	of	safety	(an	

equivalent	level	of	safety)	in	which	Congress	envisioned	that	the	FAA	must,	by	

exemption,	allow	commercial	operations	of	UASs	to	commence	immediately.	Also	due	

to	the	size	of	the	UASs	and	the	restricted	areas	in	which	the	relevant	UASs	will	operate,	

approval	of	the	application	presents	no	national	security	issue.	Given	the	clear	direction	

in	Section	333	of	the	Reform	Act,	the	authority	contained	in	the	Federal	Aviation	Act,	as	

amended;	the	strong	equivalent	level	of	safety	surrounding	the	proposed	operations,	

and	the	significant	public	benefit,	including	enhanced	safety,	reduction	in	environmental	

impacts,	including	reduced	emissions	associated	with	allowing	UASs	for	movie	and	

television	operations,	the	grant	of	the	requested	exemptions	is	in	the	public	interest.	

Accordingly,	the	applicant	respectfully	requests	that	the	FAA	grant	the	requested	

exemption	without	delay.	

AIRCRAFT	AND	EQUIVALENT	LEVEL	OF	SAFETY	

The	applicant	proposes	that	the	exemption	requested	herein	apply	to	civil	aircraft	that	

have	the	characteristics	and	that	operate	with	the	limitations	listed	herein.	These	

limitations	provide	for	at	least	an	equivalent	or	even	higher	level	of	safety	to	operations	

under	the	current	regulatory	structure	because	the	proposed	operations	represent	a	

safety	enhancement	to	the	already	safe	movie	and	television	filming	operations	

conducted	with	conventional	aircraft.	
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These	limitations	and	conditions	to	which	CopelandRED	LLC agrees	to	be	bound	when	

conducting	commercial	operations	under	an	FAA	issued	exemption	include:	

1. The	UAS	will	weigh	less	than 55 lbs	and	not	exceed	a	GS	above	87 knots.

2. Flights	shall be	operated	within	VLOS of	pilot	and	VO.

3. FPV	shall	only	be	used	through	a	monitor.	The	use	of	FPV	goggles	is	not	

authorized.

4. The	PIC	shall	perform	a	preflight	inspection	of	the	UAS	and	ground	station	prior	

to	each	flight	as	outlined	in	the	POH.	

5. Any	maintenance	conducted	on	a	production	UAS	that	includes	the	avionics,	

power	distribution,	motors	or	a	change	of	radio	control	hardware	shall	perform	a	

Functional	Check	Flight	(FCF)	prior	to	a	production-flying	mission	as	outlined	in	

the	UAS	maintenance	manual. The	certified	maintenance	technician	shall	make	

an	entry	in	the	maintenance	log	that	an	FCF	was	completed	and	the	UAS	is	Full	

Mission	Capable	(FMC)	as	outlined	in	the	maintenance	manual.

6. Maximum	total	flight	time	for	each	operational	flight	will	be	30	minutes.	Flights	

will	be	terminated	at	25%	battery	power	reserve	should	that	occur	prior	to	the	

30	minute	limit.

7. CopelandRED	LLC	has	established	an	approved	aircraft	manual	(POH)	that	

addresses	the	aircraft	and	component	overhaul,	replacement	and	inspection	of	

parts.	A	manufacturers	aircraft	manual	does	not	exist	for	the	Cinestar aircraft.	

8. Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	AGL.

9. Minimum	crew	for	each	operation	will	consist	of	the	UAS	Pilot/Camera	Operator	

and	VO.

10. UAS	pilot	will	be	an	FAA	licensed airman	with	at	least	a	private	pilot	certificate	

and	a third	class	medical and	a	current	BFR	as	outlined	in	the	SOP’s.	VO	shall	

third	class	medical and	have	passed	the	VO	certification	course	established	by	

CopelandRED	LLC.

11. Airman	flying	UAS	for	commercial	purposes must	have	logged	a	minimum	of	50	

take-off	and	landings,	25	hours	PIC	in	UAS	type	aircraft.	The	PIC	shall,	within	the	

preceding 90	days,	performed	a	minimum	of	three	take-offs	and	landings,	and	

flown	the	same	make	and	model	for	a	minimum	of	5	hours	prior	to	a	production	

flight.	The	POH	covers	three	models.	Cinestar:	Octocopter,	Hexacopter	and	

Quadcopter.

12. UAS	pilot	will	be	the	PIC	and	shall	use	the	radio-based	telemetry	at	the	ground	

station	to	read	aircraft	systems	status.	(Speed,	Altitude	AGL,	GPS	position,	

Heading	and	distance	from	home.)

13. The	UAS	will	only	operate	within	a	controlled	area	as	defined	in	the	Manual.	

14. A	“Flight	Profile	Briefing”	will	be	conducted	prior	to	each	flight.	All	production	

personnel	performing	duties	within	the	boundaries	of	the	safety	perimeter	shall	

be	a	part	of	the	briefing.	Communication	devices	such	as	hand	held	radios;	cell	

phones	and	visual	depictions	are	acceptable	means	for	conducting	the	briefing	

as	athletes	and	crew	may	be	on	a	route.

15. The	operator	shall	file	an	FAA	Form	7711-1,	or	its	equivalent,	as	modified	in	light	

of	the	requested	exemption,	with	the	appropriate	FSDO.
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16. The	operator	will	obtain	consent	of	all	persons	involved	in	the	filming	and	ensure	

that	only	consenting	persons	will	be	allowed	within	100	feet	of	the	flight	

operation.

17. The	operator	will	submit	a	written	Plan	of	Activities	to	the	FSDO	three	days	prior	

to	the	proposed	shoot.

18. Pilot	and	VO	will	maintain	currency	as	outlined	in	the	CopelandRED	LLC	SOP’s.

19. PIC	and	VO	will	establish	and	maintain	verbal communication	during	each	flying	

mission.	

20. CopelandRED	LLC	will	obtain	written	and/or	oral	permission	from	the	relevant	

property	holders prior	to	flight	operations.

21. All	required	permission	and	permits	shall be	obtained	from	local,	territorial,	

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

appropriate	governmental	agencies.

22. If	the	UAS	loses	communications,	the	PIC	and	VO	will	walk	toward	the	aircraft	

until	communications	can	be	established.	In	the	even	that	communications	can	

not	be	established,	the	flight	control	has	been	programmed	to	“Return	to	Home”	

position	and	land	within 2 minutes	or	a	battery	percentage	remaining	of	30%.	In	

the	event	that	GPS	becomes	unavailable,	the	aircraft	will	be	landed as	soon	as	

practical	and	an	entry	in the	maintenance	log	will	be	made.	(GPS	not	required	for	

Mikorkopter	Avionics	to	maintain	safety	of	flight.)

23. If	an	unsafe	condition	persists,	all	UAS	operations	will	be	aborted	until	resolved.

14	C.F.R.	Part	21,	Subpart	H:	Airworthiness	Certificates	14	C.F.R.	91.203	(a)	(1)

As	per	CopelandRED	LLC	aircraft	POH	for	the	Cinestar	Aircraft,	we	meet	the	

requirements	of	the	exemption.	UAS	to	be	operated	shall	be	less	than	55	lbs,	

unmanned,	will	not	carry	explosive	or	flammable	items	and	operates	within	the	confines	

of	CopelandRED	LLC	SOP’s	and	aircraft	POH.

14	C.F.R. 45.23	(b): Aircraft	Marking

All	CopelandRED	LLC	aircraft,	for	the	use	of	production,	shall	be	marked	with	a	serial	

number	and	company	identification. Labels	will	be	a	height	of	one	inch. (ie:	RED003,	

CopealndRED	LLC,	425.301.2110)

14	C.F.R. 61.113	(a)	&	(b):	Private	Pilot	Privileges	and	Limitations:	Pilot	in	Command

CopelandRED	LLC	observes	previous	exemptions	to	a	commercial	pilot	certificate	and	

therefore	requests	the	same	exemption.

14	C.F.R. 91.7(a):	Civil	aircraft	airworthiness

CopelandRED	LLC	shall	only	fly	aircraft	signed	off	as	“Airworthy”	as	outlined	in	the	

company	SOP’s	and	aircraft	POH.

14	C.F.R. 91.9	(b)	(2):	Civil	Aircraft	Flight	Manual	in	the	Aircraft

CopelandRED	LLC	shall	have,	at	the	ground	station,	a	digital	POH	for	the	aircraft	being	

flown.

14	C.F.R. 91.103:	Preflight	Action

The	PIC	will	complete	a	preflight	inspection	prior	to	each	flight	as	outlined	in	the	POH.
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14	C.F.R. 91.109:	Flight	Instruction

CopelandRED	LLC	shall,	in	accordance	with	the	company	Standard	Operating	Procedures	

(SOP’s),	utilize	airman	that meet	the	standards	of	this	exemption	and	company	training	

program.	We	observe	the	exemption	provided	and	granted	by	other	applicants.

14	C.F.R. 91.119:	Minimum	Safe	Altitudes

CopelandRED	LLC	will	comply	at	all	times	the	requirement	to	fly	below	400	feet	MSL.	We	

observe	the	exemption	provided	and	granted	by	other	applicants.

14	C.F.R. 91.121:	Altimeter	Setting

Prior	to	motor	start,	the	PIC	shall	accomplish	a	Flight	Control/Navi/GPS	calibration	that

sets	the	GPS	“Home”	location,	zero	altitude,	and	heading	as	outlined	in	the	POH.	As	

observed	in	previously	granted	exemptions,	this	complies.

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

CopelandRED	LLC	will	limit	flights	to	30	minutes	or	25%	remaining	battery	power,	

whichever	happens	first	as	outlined	in	the	SOP’s.	We	observe	the	exemption	provided	

and	granted	by	other	applicants.

14	C.F.R. 91.203	(a)	&	(b):	Carrying	Civil	Aircraft	Certification	and Registration

As	outlined	in	the	POS,	CopelandRED	LLC	will	maintain	a	digital	copy	of	all	pertinent	

documents	that	will	be	kept	at	the	base	station	during	operations.	We	observe	the	

exemption	provided	and	granted	by	other	applicants.

14	C.F.R. 91.405	(a); 407	(a)	(1);	409	(a)	(2);	417	(a)	&	(b):	Maintenance	Inspections

CopelandRED	LLC	has	developed	a	maintenance	program	for	company	UAS	type	aircraft.	

We	require	an	FAA	certified	A&P	mechanic	to	certify	the	UAS	for	flight.	All	maintenance	

actions	and	will	be recorded	in	the	aircraft	maintenance	log.	All	maintenance	personnel	

shall	follow	UAS	guidance	IAW	REDUASMTX	(document).	We	observe	the	exemption	

provided	and	granted	by	other	applicants.

CopelandRED	LLC	will	comply	with	all	current	and	future	directives	provided	by	the	

FAA	with	regard	to	UAS	operations.