UNITED STATES OF AMERI CA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHI NGTON, D

. C

.

**IN THE MA TTER OF THE PETITION FOR EXEMPTION OF:** 

**John L. Lewis III FOR A**  **N EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF**

**TITLE 14 OF THE CODE OF FEDERA**  **L REGULA TIONS**  **SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), A**  **ND 91.417(a) & (b) CONCERNING COMMERCIA L**  **OPERA TION OF**  **CHEERSON CX 20 UNMANNED A**  **IRCRA FT SYSTEMS** 

**PURSUA NT TO SECTION 333 OF**  **THE FAA MODERNIZA** **TION A ND REFORM A**  **CT OF 2012**

**(PUBLIC LA**

**W 112 -**  **95)**

Submitted on December 1 8 , 2015 John L . Lewis III Archer Photograph y 3947 Flora Ave. Kansas City , MO Tel: (816 ) 591

- 08712 **TA BLE OF CONTENTS**  Page GLOSSARY OF ABBREVIATIONS................. ..................................................................3 SUMMARY...................................................................................................................... .....4 IN TRODUCTION AND INTERESTS OF PETITIONER............ ........................................4 BACKGROUND................................................................................................................... .4 BASI S FOR PETITION................................................................ .........................................5 NAME AND ADDRESS OF PETITIONER.............................. ...............................6 THE SPECIFI C SECTIONS OF 14 C.F.R. FROM WHI CH ARCHER PHOTOGRAPHY SEEKS EXEMPTI ON ...............

...................... .......... 6 THE EXTENT OF RELIEF ARCHER PHOTOGRAPHY SEEKS AND THE REASON ARCHER PHOTOGRAPHY SEEKS THE RELIEF ..................... ...9 THE REASONS WHY GRANTING ARCHER PHOTOGRAPHY’S REQUEST WOULD BE IN THE PUBLIC INTEREST ...........

....... ................... ...... ..............11 THE REASONS WHY GRANTING THE EXEMPTI ON WOULD NOT ADVERSELY AFFECT SAFETY..................................................................... .....13 SUMMARY THAT CAN BE PUBLISHED INTHE FEDERAL REGI STER......23 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT ARCHER PHOTOGRAPHY’S REQUEST ........ .2 4 CONCLUSION............................................................................................... .....................2 5 APPENDI CES........................................................................

. ................ 263 **GLOSSARY OF ABBREVIATIONS** AG L Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Avi ation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace Sy stem PI C Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SO Safety Observer S OP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft Sy stem VFR Visual Flight Rules VLOS Visual L ine of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing4 **SUMMA RY**  I seek exemption f

rom the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft Sy stem pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit me to operate an Unmanned Aircraft Sy stem (UAS) for the commercial purpose of conducting aerial video and photograph y for wedding videography , real estate photograph y , construction, structure inspection, special events, forestry practices , and landscape over certain areas of the United States. **INTRODUCTION AND INTERESTS OF THE PETITIONER**  I provide clients with expertise and knowledge in advanced technologies and marketing with solutions to increase efficiency , produ ctivity and effectiveness. I also provide clients with the highest quality digital and print content for use in their own commercial, personal, and non

- profit multimedia projects. My objective is in aerial video and photograph y operation s is to provide hi gh quality imaging for a variety

of Real Estate, Oil & Gas industry , forestry , comme rcial, construction, structure inspection, public, and residential uses, specifically targeting:  Real Estate  Oil & Gas  Construction  Forestry

Practices  Photograph y  In crease public knowledge of UAS and promote safe UAS operations. **BA CKGROUND**  Unmanned Aircraft Sy stems: Cheerson CX

- 20 I seek an exemption to operate Cheerson CX

- 20 sy stems for compensation or hire within the NAS. The Cheerson CX

- 20 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone s ys tems. The Cheerson CX

- 20 has a maximum gross weight of approximately 1280 gram , while having a wingspan of 20 inches , height of 8 inches, and a m aximum speed of approximately 16 knots. The Cheerson CX

- 20 UAs are equipped with four main rotors; driven by L ithium Poly

mer battery

powered electric motors. The Cheerson CX

- 20 UAs that will be operated by me will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration , and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

.5 **BA SIS FOR PETITION**  Petitioner, John L . Lewis III , pursuant to th e provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereb y petitions the Administrator to commerciall y operate the C heerson CX

- 20 UASs in the National Airspace Sy stem (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, I will meet the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingl y, I request relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only appl y to aircraft with an airworthiness certificate. I submit that the requested relief is proper since an equivalent level of safety will be ensured. I will use my

experience to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log , and Cheerson CX

- 20 In struction Manual). Furthermore, I will document and maintain all maintenance records for the Cheerson CX

- 20 UASs. Relief from certain requirements of Section 61.113(a) and (b), entitled Priv ate pilot privileges and limitations: Pilot in command, is requested by me to the extent necessary to allow a Pilot in Command (PI C) by meeting minimum flight

- hour and currency requirements, that the PI C is able to safely operate the Cheerson CX

- 20 UASs i n a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. I seek relief from Section 91.7(a), entitled Civil aircraft airworthiness , because th e Cheerson CX

- 20 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, I submit that I will ensure that the 3 UASs are in an airworth y condition, prior to every flight, b y determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and Cheerson CX

- 20 Instruction Manual), and that the aircraft are in a condition for safe flight. I also seek an exemption from the requirements of Section 91.121, entitled Altime ter Settings , as the Cheerson CX

- 20 UAs will not have a ty pical barometric altimeter onboard. However, altitude information of the Cheerson CX

- 20 UAs will be provided to the PI C via Global Positioning System (GPS) equipment and radio communications teleme try data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with my operation of the Cheerson CX

- 20 UASs within visual line of sight, at or below 4 00 feet AGL, will ensure a level of s afety

equivalent to Section 91.121. Additionally , I seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. I submit that safety will not be affected b y operation of the Cheerson CX

- 20 UAs during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery6

power to fl y for a total duration of approximately 1 5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 11.81, Archer Photograph y provides the following information in support of its petition for exemption: **A. Name A**  **nd Ad**  **dress Of The Petitioner.** The name and address of the Petitioner and point of contact is: John L . Lewis III Archer Photograph y 3947 Flora Ave. Kansas City , MO 64030 Tel: (816) 591

- 0871 Email: archerkc@ yahoo.com **B. The Spec ifi**  **c Sections Of 14 C.F.R. f rom**  **Which John L. Lewis III**  **Seeks Exemption.**  **1. I Seek**  **Exemption From The Requirements Of Section 61.113(a) A**  **nd (b).**  Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PI C) of an aircraft that is carrying passengers or propert y for compensation or hire; nor may

that person, for compensation or hire, act as PIC of an aircraft. (b) A private pilot may , for compensation or hire, act as PIC of an aircraft in connection with an y business or emplo ym ent if

— (1) The flight is only

incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property

for compensation or hire. **2. I Seek**  **Exemption From The Requirements Of Section 91.7(a).**  Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following: (a) No person may

operate a civil aircraft unless it is in an airworthy condition. **3. I**  **Seek Exemption From The Requirements Of Section 91.121.** Section 91.121, entitled Altimeter settings , subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, b y reference to an altimeter that is set, when operating

--7 (1) Below 18,000 feet MSL , to
-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)( i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure. **4. I Seek**  **Exemption From The Requirements Of Section 91.151(b).** Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection (b), states the following: (b ) No person may begin a flight in a rotorcraft under VFR condition s 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, to fly after that for at least 20 minutes. **5. I Seek**  **Exemption From The Requirement Of Sect ion 91.405(a).**  Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator of an aircraft

— (a) 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[.]
**6. I Seek**  **Exemption From The Requirements Of**  **Section 91.407(a)(1)** Section 91.407, entitled Operation after maintenance, preventi ve maintenance, rebuilding, or alteration , subsection (a)(1), states the following: (a) No person may

operate any

aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to s ervice b y a person authorized under § 43.7 of this chapter[.]8 **7. I Seek**  **Exemption From The Requirements Of Sections 91.409(a)(1) An**  **d 91.409(a)(2).** Section 91.409, entitled Inspections , subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service b y a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. **8. I Seek**  **Exemption From The Requirements Of Sections 91.417(a) An**  **d 91.417(b).** Section 91.417, entitled Mai ntenance records , subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this se ction: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propell er, rotor, and appliance of an aircraft. The records must include

-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certi ficate number of the person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of lif e - limited parts of each airframe, engine, propeller, rotor, and appliance.9 (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for e ach, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed b y § 43.9(d) of this chapt er for each major alteration to the airframe and currentl y installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of th is section shall be retained until the work is repeated or superseded b y other work or for 1 ye ar after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time th e aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

**C. The Extent Of Relief I Seek**  **An d**  **The Reason I Seek**  **The Relief. 1. Extent Of Relief**  **John L. Lewis III Seek**  **s An**  **d The Reason John L.**  **Lewis III Seek**  **s Relief**  **From Section 61.113(a) A nd (b).**  Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in comm and, is requested to the extent necessary to allow a PI C holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire.10 This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may , for compensation or hire, act as PI C of an aircraft in connection with an y business or employ ment if: (1) The flight is only incidental to that business or employ

ment; and (2) The aircraft does not carry passengers or propert y for compensation or hire. As set forth more full y below, I submit that an equivalent level of safety will be maintain ed because no PIC will be allowed to operate the Cheerson CX

- 20 UAS except for me. Further, I submit that all flights of the Cheerson CX

- 20 UASs, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to John L . Lewis III an d ( 2) will not carry passengers or propert y for compensation or hire.

**2. Extent Of I Seek**  **And The Reason I Seek**  **Relief From Section 91.7(a).** Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow John L . Lewis III to determine that the Cheerson CX

- 20 UASs are in airworth y condition prior to every flight b y ensuring that the UAS is in compliance with the operating documents (i.e., Operations Manual, Monthly Maintenance Log, and Cheerson CX

- 20 Instr

uction Manual). I seek the requested relief because the Cheerson CX

- 20 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, I will ensure that the Cheerson CX

- 20 UASs are in airworthy condition based upon its compliance with the operating documents (i.e ., Monthly Maintenance Log, and Cheerson CX

- 20 Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limit ations below. **3. Extent Of Relief I Seek**  **An d The Reason**  **I Seek Relief From Section**  **91.121.** Relief from Section 91.121, entitled Altimeter settings , may be required to allow flight operations of the Cheerson CX

- 20 UASs, which utilize a barometric pressur e sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PI C at the ground control station (GCS). Since the FAA requires that an y altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), I seek the requested relief because the Cheerson CX

- 20 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply

with the applicable conditions and limitations stated below. As more full y set forth herein, an equivalent level of safety will be maintained since the Cheerson CX

- 20 UAs are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PI C with altitude information of the UA on the heads

- up display of the GCS.11 **4. Extent Of Relief I**  **Seek A nd The Reason**  **I Seek Relief From Section**  **91.151(b).** Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions , is requested to the extent required to allow flights of the battery powered Cheerson CX

- 20 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 15 minutes to the first point of intended landing and, assuming n ormal cruising speed, to fl y after that for at least 4.5 minutes. I seek the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered Cheerson CX

- 20 UAs will severel y constrain the practicality o f an y aerial video or still photo flight operations that I proposes to conduct pursuant to this Petition. Significantl y, as set forth below, the technical specifications of the Cheerson CX

20 UASs, the Cheerson CX

- 20 operating documents, and my proposed operating limitations, ensure that I will safely operate the battery

powered Cheerson CX

- 20 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fl y for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. **5. Extent Of Relief I Seek**  **An d The Reason**  **I Seek Relief From Sections**  **91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), A nd 91.41**  **7(a) & (b).** Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only appl y to aircraft with an airworthiness certificate, I request relief from these Sections because the Cheerson CX

- 20 UASs do not require airworthiness cer tificates. As set forth more fully

below, the Cheerson CX

- 20 UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingl y I will perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Operations Manual, Monthly Maintenance Log, and Cheerson CX

- 20 Instruction Manual). Furthermore, I will document and maintain all maintenance records for the Cheerso n CX

- 20 UASs. **D. The Reasons Why**

**Granting John L. Lewis III**  **Request Would Be In The Public Interest; That Is, How It Would Benefit The Public A**  **s A Whole.**  Granting the present Petition will further the public interest b y allowing John L

. Lewis III to s afel y, efficiently , and economically perform aerial video and photography for real estate, forestry

practices , special events, and landscape over certain areas of the United States. Additionally , use of the Cheerson CX

- 20 UASs will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of my proposed operation of the Cheerson CX

- 20 UASs will be realized without implicating an y privacy

issues.12 **1. The Public Will Benefit From Decreased Conge stion Of The NA** **S.** The Cheerson CX

- 20 UAs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery

. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a Cheerson CX

- 20 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property

in the air and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused b y arriving and departing aircraft will be reduced. The Cheerson CX

- 20 UAs do not require an airport to takeoff or land. Likewise, a reduction of manned aircra ft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

**2. The Public Will Benefit From The S afety A**  **nd Efficiency Of The**  **Cheerson CX -**  **20 UA** **Ss.** Conducting aerial acquisitions with the Cheerson CX

- 20 UASs, instead of manned aircraft, will greatl y benefit the public by drastically

reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery

power and electric motors, the Cheerson CX

- 20 UASs produce no air pollution, and is the most viable environmentall y conscious alternative to the cabin class, six cylinder intern al combustion engine aircraft that are typically utilized for aerial video and photograph y, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The Cheerson CX

- 20 UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather than an internal combustion engine. By using the Cheerson CX

- 20 UASs to perform aerial acquisitions, the substantial risk to life and property i n the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completel y eliminated. Aside from the lack of flight crew members located onboard the aircraft, the Cheerson CX

- 20 UAs (weighing approximately 2 pounds 11 ounces, at maximum gross weights with lengths of 19 inches, widths of 19 inches, and with no fuel on board), has less phy sical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that ty picall y conduct similar operations (weighing approximately

6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity

of 180 gallons). **3. Performing Aerial Video and Photography Operations With Th e**  **Cheerson CX**  **- 20**  **UASs Will Benefit The Economy.** In addition to being safe and efficient, the Cheerson CX

- 20 UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As13

such, operation of the Cheerson CX

- 20 UA Ss will allow United States based companies, like mine , to remain competitive and contribute to growth of the U.S. economy

. Specificall y, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory

actions phasing out l eaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery

powered Cheerson CX

- 20 UASs is one such technology that not only allows companies greater operational fl exibility compared to manned aircraft, but provides such flexibility

without the high operational cost of a traditional manned aircraft. By operating the Cheerson CX

- 20 UASs, companies such as I , can remain competitive and profitable, and therefore, provi de greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. econom y. Improved financial performance of U.S. companies, through commercial use of the Cheerson CX

- 20 UASs, provides a stable workforce that in creases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.

**4. There A re No Privacy**  **Issues.** Similar to the manned aerial acquisition flight operations that have been conducted for decades, I proposed operation of the Cheerson CX

- 20 UASs will not implicate an y privacy issues. Specificall y, the Cheerson CX

- 20 UASs will be operated onl y in compliance with operati ng documents (i.e., the Operations Manual, Monthly Maintenance Log, and Cheerson CX

- 20 Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, inc luding the minimum altitude requirements of 14 C.F.R. § 91.119. **E. The Reasons Why**

**Granting The Exemption Would Not A dv**  **ersely A**  **ffect Safety**  **, Or How The Exemption Would Provide**  **A Lev**  **el Of Safety At** **Least Equal To That Provided By**  **The Rule From Which I See**  **k Exemption.**  **1. Reasons Why**

**The Cheerson CX**  **- 20**  **UAs Meet The Conditions Of The**  **FAA Modernization and Reform A** **ct of 2012 (FMRA ) Section 333.**  In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft an d its operation, my operation of the Cheerson CX

- 20 UASs meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specificall y, FMRA Section 333 states the following, in part: (a) In General.
-- Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft14 systems may operate safely in the na tional airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. (b) Assessment of Unmanned Aircraft Systems.
-- In making the determination under subsection (a), th e Secretary shall determine, at a minimum
-- (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United S tates Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.
-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the n ational airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, I submit that the Cheerson CX

- 20 UASs can operate safel y in the NAS pursuant t o FMRA Section 333, as demonstrated b y: (a) the characteristics of the Cheerson CX

- 20 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

**a. The Specifications Of The Cheerson CX**  **- 20**  **UA Ss Demonstrate Its**  **Safe Charact eristics.**  The Cheerson CX

- 20 UASs do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability

.

**i. Technical Specifications Of The Cheerson CX**  **- 2**  **0 UA** **Ss.** The technical specifications of the Cheerson CX

- 20 UASs are set forth b y the Cheerson CX

- 20 Specifications and Data Sheet

.

**ii. The Cheerson CX**  **- 20**  **UA Ss A**  **utonomous Flight A nd Navigation**  **Modes Enable The UA Ss To Remain Within A**  **Defined Operational**  **Ar ea.**  The Cheerson CX

- 20 UASs may be operated in both manual and fully autonomous flight mod es Cheerson CX

- 20 . A complete description of the flight and navigational modes15

of the Cheerson CX

- 20 UASs is provided at pages 7

- 8 of the Cheerson CX

- 20 User Manual

. **iii. The Cheerson CX**  **- 20**  **UA Ss A**  **re Designed For A utomatic** 

**Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.**  When the Control L ink is lost, the Cheerson CX

- 20 UAs will remain stationary , in flight, for 3 seconds or more. If, after 3 seconds, the Cheerson CX

- 20 UAs do not reacquire control link data from the GCS, the UAs will assume that the Control L ink is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeof

f position and shutdown. A complete description of the Failsafe Functions of the Cheerson CX

- 20 UAS are set forth on page 8 of the Cheerson CX

- 20 User Manual.

**a . Flights Of**  **Cheerson CX -**  **20 UA** **Ss Will Be Conducted Pursuant To Specific Operating Limitation**  **s.** In seeking this exemption, I propose to commercially operate Cheerson CX

- 20 UASs for the purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations: 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: Cheerson CX

- 20 Unmanned Aircraft Sy stems. Proposed operations of any othe r aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography. 3. The UAs may

not be flown at an indicated airsp eed exceeding 20 knots. 4. The UA must be operated at an altitude of no more than 4 00 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved b y ATC. All altitudes r eported to ATC must be in feet AGL. 5. The UAs must be operated within visual line of sight (VLOS) of the PI C at all times. This requires the PIC to be able to use human vision unaided by an y device other than corrective lenses, as specified on the PI C’s FAA

- issued airman medical certificate. 6. The use of first person view (FPV) b y the PI C or safety observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PI C alway s maintains VL OS capability

. The SO and PI C must be able to communicate verbally at all times. Electronic16 messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her d esignation for the duration of the flight. The PI C must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assisting the PI C with seeing and avoiding other air traffic an d other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments. 9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon reque st. If a discrepancy

exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be fo llowed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised docume nts to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon whi ch the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PI C must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properl y documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PI C who conducts the functional test flight must make an entry in the aircraft records. 12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents. 13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts17 must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service. 15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspec tions. 17. The PI C must possess at least a private pilot certificate and at least a current third

- class medical certificate. 18. The operator may

not permit any

PIC to operate unless the PI C meets the operator’s qualification criteria and demonstrates the ability to safel y operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualifi cation flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicate d training sessions. During training, proficiency , and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PI C must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 19. UAS operations may

not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA may

not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronauti cal chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to th e Administrator upon request. 21. The UA may

not be operated less than 4 00 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PI C. 22. If the UA loses communications or loses its GPS si gnal, it must return to a pre

determined location within the planned operating area and land or be recovered in accordance with the operating documents.18 23. The PI C must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 24. The PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a No tice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and po tential transponder requirements. 26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

- Number) markings in accordance with 14 C.F.R. p art 45, Subpart C. Markings must be as large as practicable. 27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate governm ent oversight agency requirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or an y law enforcement official upon request. 29. The UA must remain clear and yi eld the right of way to all manned aviation operations and activities at all times. 30. The UAS may

not be operated b y the PIC from any moving device or vehicle. 31 . Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PI C, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that suffi ciently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately

and/or;19 b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PI C has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and; c. Operations nearer to the PI C, SO, operator trainees or essential persons do not present an undue hazard to those p ersons per § 91.119(a). 32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Offic e (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. **2. Reasons Why**

**A n Exemption From The Requirements O**  **f Section 61.113(a) A**  **nd (b) Would Not A dversely**  **A ffect Safety** 
**.** I submit that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PI C will be allowed to operate the Cheerson CX

- 20 UASs except John L . Lewis III and that PI C has demonstrated, by meeting minimum flight

- hour and currency

requirements, that the PI C is able to safel y operate the Cheerson CX

- 20 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering my proposed area of operations, and the operating limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements ( See Exemption No. 11062); and the airmanship skills necessary

to safely operate the Cheerson CX

- 20 UAS, I submit that the additional manned airmanship experience of a commerciall y certificated pilot would not correlate to the airmans hip skills necessary for my specific proposed flight operations. The FAA has previously

granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062 , 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). I will not allow any

PIC to operate the Cheerson CX

- 20 UAS except me and that PI C has demonstrated, by meeting minimum flight

- hour requirements or the Cheerson CX

20 UAS training and currency requirements, that the PI C is able to safel y operate the Cheerson CX

- 20 UAS in a manner consistent with this exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specificall y, the PI C must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a20

minimum of 5 hours of those hours a s a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during my proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No . 11062, the PI C must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be in clusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary

to safely conduct the p etitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency , and experience

- building flights can also be condu cted under the grant of exemption to accomplish the required flight time. During training, proficiency , and experience

- building flights the PI C is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 111 38 at page 15. Accordingl y, I will ensure safe operations b y not allowing an y P IC to operate the Cheerson CX

- 20 UAS unless that PI C has demonstrated, by meeting minimum flight

- hour and currency

requirements, that the PI C is able to safel y operate the Chee rson CX

- 20 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. **3. Reasons Why**

**A n Exemption From The Requirements Of Section**  **91.7(a) Would Not A** **dv ersely** **A ffect Safety.**  The equivalent level of safety established b y Section 91.7(a) will be maintained because prior to every

flight, I will ensure that the Cheerson CX

- 20 UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations herein. Additionally , the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g.21

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **4. Reasons Why**

**A n Exemption From The Requirements Of Section**  **91.121 Would Not A dv**  **ersely A**  **ffect Saf ety** 
**.** The equivalent level of safety established b y Section 91.121 will be maintained because the altitude information of the Cheerson CX

- 20 UAs will be provided to the PI C via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with my operation of the Cheerson CX

- 20 UAs within visual line of sight, at or below 4 00 feet AGL, will ensure a level of safety equivalent t o Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UASs at ground level. The FAA has previously

granted r elief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11 159, 11160, 11161). **5. Reasons Why**

**A n Exemption From The Requirements Of Section**  **91.151(b) Would Not A dv**  **ersely A**  **ffect Safety**
**.** A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the Cheerson CX

- 20 UASs; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly , I will ensure that it will safel y operate the battery powered Cheerson CX

- 20 UAs during daylight hours in VFR conditions, with enough battery

power to fly

for a total duration of 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Here, as in Ex emption No. 11109, the technical specifications of the Cheerson CX

20 UASs; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b ). Furthermore, safety will be ensured as the Cheerson CX

- 20 UASs provide audible and visual warnings to the PI C at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery

power, and again at approximately 10% remaining battery power. At the criticall y low battery level, the Cheerson CX

- 20 UASs will descend and land automatically

. Significantl y, previous exemptions granted b y the FAA concerning Section 91.151 establish that safety is not adve rsel y affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 1 0650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063,22

11064, 11065, 11066, 1106 7, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **6. Reasons Why**

**A n Exemption From The Requirements Of Sections**  **91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), A nd 91.417(a) & (b)**  **Would Not A dv**  **ersely A ffect Saf** **ety**
**.** In seeking this exemption, I submit that the equivalent level of safety with regard to the regulatory

maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met bec ause Archer Photograph y will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., the Operations Manual, Monthly Mainten ance Log, and Cheerson CX

- 20 Instruction Manual). Furthermore, I will document and maintain all maintenance records for the Cheerson CX

- 20 UASs. Likewise, the exemption sought will not adversel y affect safety because I will use my experience to perform m aintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safety established by

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the Cheerson CX

- 20 UASs will be performed b y me . Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantl y, previous exemptions granted b y the FAA concerning Sec tions 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversel y affected when the technical characteristics and operating limitations of the UAS are considered. In consideration of my proposed operating lim itations, the operating documents, and the technical aspects of the Cheerson CX

- 20 UASs, I submit that safety will not be adversel y affected b y granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previousl y granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 1 1156, 11157, 11158, 11159, 11160, 11161). **7. The FAA**

**Ma y**  **Prescribe A ny** 

**Other Conditions For Safe Operation.** In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions , I reques t that the FAA prescribe special conditions for the intended operation of the Cheerson CX

- 20 UASs, which contain such safety standards that the Administrator finds necessary to establish a level of safety

equivalent to that established by 14 C.F.R. Part 21 , Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video and photograph y over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national sec urity; and further, provides the authority for such23 UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe s pecial conditions pursuant to 14 C.F.R. § 21.16, for operation of the Cheerson CX

- 20 UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions , states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller beca use of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such s afety

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary

to establish a level of safety equivalent to that established in the regulations.
See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C. F.R. § 21.16, the FAA may prescribe special conditions for L eading Edge’s intended operation of Cheerson CX

20 UASs, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established b y 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

**F. A**  **Summary**

**That Can Be Published In The Federal Register,**  **stating: The Rules From Wh**  **ich John L. Lewis III**  **Seeks Exemption:** John L. Lewis III seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). **A Brief Description Of T**  **he Nature Of The Exemption John L. Lewis**  **III Seeks:**  This exemption will permit John L. Lewis III to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States

.24

**G. An**  **y Ad**  **ditional Information, Views, Or A rguments A**  **vailable To Support John L. Lewis’**  **Request.** This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determin e if certain UAS may operate safely

in the NAS. As such, John L . Lewis ’ request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, John L. L ewis III will operate the Cheerson CX

- 20 UASs safel y in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.25 **CONCLUSION**
As set forth herein, Jo hn L. Lewis III seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the Cheerson CX

- 20 UASs commercially , without an airworthiness certificate, for the limited purpose of conducting aerial video and photograph y over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also a dvancing the interests of the public, b y allowing John L

. Lewis III to safel y, efficiently , and economically operate the Cheerson CX

- 20 UASs commerciall y within the NAS. **WHEREFORE** , in accordance with the Federal Aviation Regulations and the FAA Moderniz ation and Reform Act of 2012, Section 333, John L . Lewis III respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit L eading Edge to operate the Cheerson CX

- 20 UASs commerciall y for the purpose of conducting aerial video and photograph y over certain areas of the United States. Date d: December 15 , 2015

Re spectfully submitted, John L . Lewis III

_________________________ John L . Lewis III 39847 Flora Ave. Kansas City , MO 64110 Tel: ( 816) 591

- 087126

Appendic es : A

– Cheerson CX

- 20 Specifications Dat a Sheet B

– Monthly

Maintenance L og

APPENDIX

– A **CHEERSON CX -**  **20 TECHNICAL**  **SPECIFICATIONS** I onl y util izes safe and reliable UASs. Cheerson is an industry leader in small UAS production. Cheerson UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit f l ight to a predetermined and set distance. In addition, Cheerson so ftware provides real

- time altitude and location information to the PI C via the linked monitor (smart phone/tablet devices) Cheerson CX

- 20 Purchased from Banggood .com Cheerson CX

- 20 Specs. **Weight (Including Battery And Propellers)**  1280 g **Diagonal Size (In cluding Propellers)**  508 mm **Max Ascent Speed** 5 m/s **Max Descent Speed** 3 m/s **Hover Accuracy** Vertical: +/

- 10cm Horizontal: +/

- 1m **Max Speed** 16 m/s (ATTI mode, no wind) **Max Altitude Above Sea Level** 6000 m27

**Operating Temperature** 0°C to 40°C **GPS Mode** GPS/GL ONASS Camera **Sensor** Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M) **Lens** FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞ **ISO Range** 100

- 3200 (video) 100

- 1600 (photo) **Shutter Speed** 8s

- 1/8000s **Image Max Size** 4000 x 3000 **Still Photography Modes** Single Shot Burst Shooting: 3/5/7 shots Auto Exposure Bracketing (AEB): 3/5 Bracketed Frames at 0.7EV Bias Time

- lapse **Video Recordin g Modes**  Cheerson CX

- 20 UHD: 4096x2160p 24/25, 3840x2160p 24/25/30 FHD: 1920x1080p 24/25/30/48/50/60 HD: 1280x720p 24/25/30/48/50/60 Phantom 3 Advanced FHD: 1920x1080p 24/25/30/48/50/60 HD: 1280x720p 24/25/30/48/50/60 **Supported SD Card Types** Micro SD Max c apacity : 64 GB. Class 10 or UHS

- 1 rating required **Max Bitrate Of Video Storage** 60 Mbps **Supported File Formats** FAT32/exFAT Photo: JPEG, DNG Video: MP4, MOV (MPEG

- 4 AVC/H.264) **Operating Temperature** 0°C to 40°C Gimbal **Controllable Range** Pitch

- 90° to +30° **Sta bilization**  3

- axis (pitch, roll, yaw) Vision Positioning28

**Max Velocity** Less than 8 m/s (when 2 m above ground) **Altitude Range** 30 cm

- 300 cm **Operating Range** 30 cm

- 300 cm **Operating Environment** Surface with clear pattern and adequate lighting (Lux > 15) Remote C ontroller **Operating Frequency** 2.400 GHz

- 2.483 GHz **Max Distance** 2000m (outdoors and unobstructed) **Video Output Port** USB **Operating Temperature** 1.1

Cheerson CX

- 20 Pre

- Flight Inspection Check List Pre

- Flight Check List  Visual inspection for defects  Batteries fully

charged and checked

- Transmitter, UAS, iPad, iPhone, approved/compatible device  Props tightened and locked  SD card in camera  Lens cap removed (As necessary)  Antennae up and parallel  Transmitter turned on (press once, release, then press and hold for 3 seconds)  Ensure Transmitter is in P Mode  UAS turned on (press once, release, then press and hold for 3 seconds)  Flick the transformation switch on transmitter up and down 4 times quickly to convert from travel mode to flight mode or use the app  Cheerson Pilot app quit and restarted, no other running apps on iPad  Tap bar at top of app (Safe to Fl y GPS) for full status  Maps are cached (move the map around, zoom in an out)  Minimum return height adjusted (check for tallest object and set accordingl y)  UAS placed in safe launch and recover position  Home point reprogrammed via app  Area clear of people / obstructions Flight Check Li st29

 Hover close for 20 seconds. Look / L isten for defects  Confirm expected stick operation  Monitor battery

power  Monitor signal strength  Keep line

- of

- si ght with UAS

o Ensure area/zone of intended flight path is clear of other aerial traffic.

o Ensure area/zone of intended flight path is clear of any electrical/power lines

o Ensure atmospheric conditions are optimal for safe operation of UAV/UAS Selec t a safe zone to “ditch” the UAV/UAS in the event an emergency landing is required

m o n t h :

_ _ _ _ _ _ _ _ _ (y e a r :

_ _ _ _ _ _ _ _ **U A**  **S $**  **# :**  **$**

**_ _**  **_ _**  **_ _**  **_ _**  **_ _**  **_** D a t e ( I s s u e ( D i s c o v e r e d D a t e ( I s s u e (

A d d r e s s e d S o ft w a r e ( U p d a t e s
A i r f r a m e (

E n g i n e s
P r o p e l l e r s
C a m e r a (G i m b a l

L a n d i n g ( G e a r
V i b r a t i o n ( D a m p e n i n g
O t h e r : **M O**  **N T**  **H L** **Y $**  **M A**  **I N**  **T E**  **N A**  **N C**  **E $** 

**L O**  **G**

I s s u e ( D e s c r i p t i o n (

& ( M a i n t e n a n c e (C o n d u c t e d M a i n t e n a n c e ( P e r f o r m e d ( B y : ( ( ( P r i n t ( & (S i g n30