1 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	Syste ms	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	all ow	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	re quested	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	televis ion	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	40 th Ave	E,	Seattle,	WA	981122 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	Secret ary	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

Secreta ry	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	nati onal	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	§4 0101	of	the	Act that	includes UASs,	from	the	requirement	that
all	civil	aircraft	must	have	a	current	airworthiness	certificate.

CopelandRED	LLC’s UA Ss	are	rotorcraft,	weighting	55	or	fewer	lbs.	including payload.	They	operate,	under	normal	conditi ons	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	o perations	will insure	that	the UAS	will	“not	create	a	hazard	to users	of	the	national	airspace	system	or	the	public.”3 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	restrict ed	areas	in	which	the	re levant 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	surroundi ng	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	exempti ons	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	ai rcraft	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	operatio ns	represent	a safety	enhancement	to	the	already	safe	movie	and	television	filming	operations
conducted	with	conventional	aircraft.4 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	onl y	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	grou nd	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	mainten ance	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	tha t	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	5 0
take

- off	an d	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	m odels.	Cinestar:	Octoco pter,	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	th e	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	modifi ed	in	light of	the	requested	exemption,	with	the	appropriate	FSDO.5 16. The	operator	will	obtain	consent	of	all	persons	involved	in	the	filming	and	ensure that	only	consenti ng	persons	will	be	allowed	with in	100	feet	of	the	flight operation.

17. The	operator	will	su bmit	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. Cop elandRED	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	obtai ned	from local, territorial,
state,	co unty	or	city jurisdictions ,	including	local	law	e nforcement,	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	th at	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 land ed 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,	Sub part	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	conf ines 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:	RED00 3, 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. 9 1.7(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.6 14	C.F.R. 91.109 :	Flight	Instruction CopelandRED	LLC	shall,	in	ac cordance	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	Altit udes 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	Co ntrol/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	maintai n	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	progra m	for	company	UA S	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.