Coe Aerial 

### & Photography, LLC Channing Coe 2608 NE 21st Ct Fort Lauderdale, FL 33305 {954) 328-2587

U. S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590 Date: Dec 16, 2015

RE: Petition ofCoe Aerial 

### & Photography, LLC for Exemption Pursuant to Section 333 ofthe FM Reform Act of2012.
Attn: To Whom It May Concern:
Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, Coe Aerial 

### & Photography, LLC, operatorofSmall Unmanned Aircraft Systems {"sUASs") equipped to conduct aerial photography and videography, hereby applies foran exemption from the listed Federal Aviation Regulations {"FARs") to allow commercial operation of its sUASs, so long as such operations are conducted within and underthe conditions outlined herein oras may be established by the FAA as required by Section 333.1.
As described more fully below, the requested exemption would permitthe operation ofsmall, unmanned and relatively inexpensive sUAS undercontrolled conditions in airspace that is 1) limited 2) predetermined and 3) controlled. The proposed exemption, ifgranted, would allowCoe Aerial 

### & Photography, LLC to conduct commercial operations ofsmall unmanned aircraft systems ("UAS") meeting orexceeding all ofthe operational and safety requirements Congress has set forth in Section 333, Page 2. Coe Aerial 

### & Photography, LLC is an aviation services company owned and run by Channing Coe. Mr. Coe currently holds a Private Pilot Single Engine Land Certificate and has been a licensed pilot for 28 years flying a multitude ofprivate aircraft and accumulated over 1500 hrs offlight time. Also, Mr. Coe has been active in Radio Controlled Aircraft for over35 years with experience in fixed wing and rotary wing aircraft, with over500 hrs flying sUAS. COe Aerial 

### & Photography, LLC plans to exploit the capabilities of Unmanned Aerial Systems to offera multitude ofservices, including: -Aerial surveying

- Event Photography/Videography -Agriculture purposes -Real Estate Photography/Videography- Aerial Filmmaking and Photography on Closed Sets -Construction site inspections and monitoring StatutoryAuthority Section 333, titled 11Special Rules for Certain Unmanned Aircraft Systems", provides a mechanism forseeking expedited FMauthorization ofsafe civil UAS operations in the NAS. Section 333{a) states thatthe FM "shall determine ifcertain unmanned aircraft systems may operate safely in the national airspace system before completion ofthe (comprehensive) plan and rulemaking required by section 332(b){1) ofthisAct orthe guidance required by section 334 ofthis Act." In Section 332{b){1), Congress made it clear that Section 333 provides a mechanism for "expedited operation . \

! lauthorization" ifseveral factors are met. Petitioner meets all requirements to permit FAA approval of commercial UAS operations.
The Petitioner Requests Relief From the Following: Regulations from which the exemption is requested: 14 C.F.R. Part 2114 C.F.R. 45.23 (b) 14C.F.R. 61.113(a) and (b) 14C.F.R. 91.7 (a) 14C.F.R. 91.9 (b) (2} 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 Page 3 14 C.F.R. 91.151(a) 14 C.F.R. 91.203 (a) 

### & (b) 14 C.F.R. 91.205 (b) 14 C.F.R. 91.215 14 C.F.R. (91.401- 91.417}
Unmanned Aircraft System (UAS) are oftentimes seen as superiorto helicopters due to the smaller devices, cheaper equipment and personnel cost, reduced noise and as such, a much smaller environmental impactwhich promotes public safety.
We are petitioning for exemption to enable Coe Aerial 

### & Photography to operate a DJIInspire Pro sUAS upgraded to the Version 1.2.0.50 firmware and equipped with atwo-axis camera gimbal and using a High-Definition camera. This sUAS has a built-in capability to limitthe height itflies above the ground and to limitthe radius ofthe distance itflies from the operator. The Inspire Pro also has the failsafe function ofthe autopilot system which means when the communication between the Main Controller and the transmitter is disconnected, the outputs ofall command sticks from controllerwill go to the center position. lfthe GPS signal is good enough, the system will automaticallytrigger a Return to Home function and will automatically land safely.
Please refertothe included DJIInspire Pro Instruction Manual forthe performance limitations and flight operations.
Aircraft weight is 6.5 lbs with battery, 2-Axis Camera Gimbal, and Camera.
A Pre-flight inspection will be performed by the PIC in accordance with the factory instruction manual. An added step will be the inspection ofthe propellers. A propellerwill be replaced ifit has any nicks and cracks with a manufacturers authorized propeller.
The sUAS will be maintained in accordance with the manufacturers instruction manual and only manufacturer's authorized replacement parts will be used. FCC Information The Inspire Pro Remote Controllers will be used for controllingthe sUAS and complies with part 15 ofthe FCC rules. Operation is subject to the following two conditions: (1} This device may not cause harmful interference, and (2} this device must accept any interference received, including interference that may cause undesired operation. The Inspire Pro radio transmitter used for controlling the sUAS is wireless technology which has been tested and found to be compliant with the applicable regulations governing a radio transmitter in the 2.400GHz frequency with a maximum transmission distance of2km. Antenna Separation Distance when operating our Inspire Pro transmitter, the PIC will maintain a separation distance ofat least 5 em between his body (excluding fingers, hands, wrists, ankles and feet) and the antenna to meet RF exposure safety requirements as determined by FCC regulations.
Pilot in Command and Observer Qualifications and Duties The PIC will maintain at least a Private Pilot Certificate and a current Class Ill medical certificate, plus at least 2 hoursflying time and 3 takeoffs and landings within 30 days in the type of UAS utilized in operations. The PIC will have at least 100 hours

### total time and at least 30 hours flying Radio Controlled ModelAircraft ofwhich will be 10 hours flying sUAS's. Training will be conducted at a local Radio Control Club flying field. Coe Aerial 

### & Photography, LLC has the abilityto provide "dual controls" utilizingtwo Inspire 1transmitters with a wireless link between the transmitters. One transmitter is designated the mastertransmitter and the othertransmitter is designated as aslave. The PIC instructor, utilizing the mastertransmitter, will be at all times be able
assume control ofthe sUAS.
The PIC is responsible forthe safe and efficient operation ofthe aircraft. Specific duties include all preflight preparation, in-flight operation, post-flight requirements, all procedures including but not limited to: Safe in-flight operations; Risk Mitigation to Persons and property; Airfield Suitability.
The Observer must have the visual acuityto observe the sUAV and be able to communicate clearly with the PIC. The Observers duties are:-- warning the PIC ofany impending obstacles in the flight path ofthe sUAS. --warningthe PIC ofany deviations in the planned flight path ofthe sUAS. --warning the PIC should any unauthorized personnel appear in the area ofthe planned flight. The Observer will have the authorityto orderthe PIC to terminate the flight should he feel the flight cannot be conducted safely. General Operating Standards

• Coe Aerial 

### & Photography, LLC will only operate its sUAS in line ofsight ofa pilot and/orobserver and will operate at sites that are a 'sufficient distance' from populated areas. Such operations will insure that the sUAS will"not create a hazard to users ofthe national airspace system orthe public."

• Before an operation ofa sUAV within 5NM ofan airport with a control tower, the control towerwill be notified to gain permission to operate the sUAS. The PIC will give the position, altitude and the times the sUAV will be operated. The sUAS will not be operated at an altitude ofover 300 feet AGL. Weather minimums will be 3 miles visibility and a 1000foot ceiling. Before an operation ofa sUAS within 5NM ofa non-towercontrolled, airportoperators will be notified and the PIC will give the right ofway to avoid flying in the proximity offull-scale aircraft. At notime will the sUAV be operated within the final approach course and the takeoffcourse ofany runway.

• Maximum flight time for each operational flight will be 30 minutes.

• Flights will be terminated at 25% battery power reserve should that occur priortothe 30 minute limit.

• The sUAV will be programmed so that itwill not be operated at an altitude of more than 400 feet AGL, and not more than 200 feet above an elevated platform from which filming is planned.

• Minimum crew for each operation will consist ofthe sUAS Pilot, and Visual Observer.

• The sUAV operated by the petitionerweighs less than 55 pounds, includingthe payload (i.e. camera, lens, and gimbals).

• The sUAV will operate at speeds of no more than 25 knots, can hover, and cansimultaneously move vertically and horizontally.

• Given the small size ofthe sUAV and the restricted sterile environmentwithin which they will operate, oursUAV operations adhere to the Reform Act's safety requirements.The UAS, powered by batteries, is smaller, lighterand more maneuverable than larger aircraft running
on combustible fuel, itoperates at lower altitudes with no people on board and will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood ofdeath orserious bodily injury. With a small payload and maximum flight time ofonly 20 minutes, this offers little or no risk to national security.
Low level oblique photos and video from several angles are far more effectivethan ground based imageryfor displaying the characteristics oflarge, complex properties with several buildings and large trees. Compared to manned aircraft, the benefits of reduced cost and improved quality ofpresentation from the UA will be valuable to and benefit many buyers and sellers of real property. Additionally, we request that we be allowed to use our system to benefit first responders nearby who might require assistance, including fire fighters, the police, the sheriff, et at., while remaining subject to all limitations cited in this application as we do so. (a) No flight will be made with a Gross weight exceeding 55 pounds; (b) All operations mustoccur in FAA Class Gairspace at no more than 400ftAGL, at an airspeed of no more than 25 knots and no furtherthan 3/4 NM from the PIC; (c) All operations must utilize avisual observer (VO). The VO and PIC must be able to communicate by voice at all times during a flight operation; (d) Operations will be restricted to flights over private property with the permission ofthe property owner; (e) All required permits will be obtained from state and local government priorto operation; (f) Coe Aerial 

### & Photography, LLC UAS aircraft will not be operated over densely populated areas; (g) Coe Aerial 

### & Photography, LLC UAS aircraft will not be operating over any open-air assembly of people; (h) Coe Aerial 

### & Photography, LLC UAS aircraft will not be operating over heavily trafficked roads; (i) Coe Aerial 

### & Photography, LLC UAS aircraft will not be operating at night. EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY Coe Aerial 

### & Photography, LLC requests an exemption from the following regulations as well as any additional regulations that maytechnically apply to the operation ofthe sUAV System:
14 CFR Part 21, Airworthiness Certificates This partestablishes the procedures forthe issuance ofan airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued forthe 

### OJI Inspire Pro under either or both ofthefollowing provisions: 21.191 Experimental certificates. Experimental certificates are issued forthe following purposes: (a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations includingflights to show compliance for issuance oftype and supplemental type certificates, flightsto substantiate major design changes, and flights to show compliance with the function and reliability requirements ofthe regulations. Since

### the experimental certificate can be used forcommercial purposes such as market surveys, sales demonstrations, and customer crewtraining, wewould expect thatan experimental certificate would permitourcommercial purpose as well. The aircraftwill notcarry persons orproperty, will notcarry fuel, and will onlyfly understrict operational requirements. Combined with the UA's lightweight, being constructed primarily ofcarbon fiber and plastic, we propose thatthe UA will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission. Ifan experimental airworthiness certificate is notappropriate forthis application, then we request an exemption of 14CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level ofsafety outlined in the previous paragraph.
14CFR 45.23 Display ofmarks; general and 45.29 Size ofmarks. These regulations provide that each aircraft mustdisplay "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilotstation. The sUAV does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration numberassigned to it bythe FAA. We propose to achieve an equivalent level ofsafety by includingtheword "EXPERIMENTAL" in the placard on the top ofthe aircraft, as shown above, wherethe PIC (Pilot In Control), VO (Visual Observer) and others inthevicinity ofthe aircraftwhile itis preparing for launch will be able to see the designation. Additionally, wefeelthatthe permanent placard discussed in the previous paragraph will providethe aircraft's registration information atthe ground station. Finally, wewill display atthe ground station a high contrast flag or bannerthatcontains the words "Unmanned Aircraft Ground Station" in letters 3 inches high orgreater. Since the aircraftwill operate within 3/4 NM ofthe ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its pointof origin.
14CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regulation providesthat no person that holds a Private Pilotcertificate mayact as pilot in Command ofan aircraftfor compensation or hire. Subparagraph {b) allows a private pilotto act as pilot in command ofan aircraft in connection with any business oremployment if: (1) The flight is only incidental to that business oremployment; and (2) The aircraft does not carry passengers or propertyforcompensation or hire. Our proposed operations require thatthe PIC must hold at least a Private Pilot Certificate with a Class Ill Medical issued bythe FAA and since the aircraft cannot carry passengers or property, we feel we meetthe intentof61.113 Subparagraph (b) even though the intent ofthis application is to conduct a business.
14CFR 91.7 Prohibitsthe Operation ofan aircraftwithout an airworthiness certificate. As no such certificate will be applicable in theform contemplated bythe FARs, this Regulation is inapplicable.
14 CFR 91.9 Civil aircraftflight manual, marking, and placard requirements. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume that the intentofthis requirement is to ensure that flight manual information is available to the aircrewwhile operatingthe aircraft. We request an exemptiontothis requirement since the aircraft is notonlytoo small to carry documentation, the documentation would not be available tothe crew duringflight operations. To obtain an equivalent level ofsafety and meetthe intentof91.9, we propose that a current, approved sUAS Flight Manual must be available tothe crew atthe ground station anytime the aircraft is in, or preparing for, flight.14CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests. The regulation states that "No person may operate a civil aircraftthat is being used forflight instruction unless that aircraft has fully functioning dual controls." Training will be conducted ata local Radio Control Club flying field. Coe Aerial 

### & Photography, LLC has the abilityto provide "dual controls" utilizingtwo Inspire Pro transmitters with awireless link between thetransmitters. One transmitter is designated the master transmitterand the othertransmitter is designated as a slave. The PIC instructor, utilizingthe master transmitter, will be at all times be able assume control ofthe sUAV.
91.119 Minimum safe altitudes: General. The regulation statesthat oversparsely populated areas the aircraft cannot be operated closerthan 500 feet to any person, vessel, vehicle, or structure. Since the typical mission ofthe sUAS would be photography or survey ofpersons, vessels, vehicles orstructures it would be necessary to operate closerthan 500 feet to the items listed. Operations will only be flown
over property or persons where permission has been obtained and careful pre-planned flight path has been performed. The aircraft will be operated at a lowaltitude allowing, ifa power unitfails, an emergency landing without undue hazard to persons or propertyon the surface. Therefore, we maintain that due to the small size ofthe UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in grantingthe exemption.
CFR 91.121 Altimetersettings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimetersetting available within 100 NM ofthe aircraft. The sUAS will always fly below 400 feet AGL and will not need to maintain cruising altitudes in orderto prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the sUAS on-board computerto the display screen held by the PIC, providing a constantly updated AGL readout.
14 CFR 91.151 Fuel requirements forflight in VFR conditions. The regulation provides that no person may begin a flight in an airplane underday-VFR conditions unless there is enough fuel to flyto the first point ofintended landing and to fly afterthat for at least 30 minutes. We feel the intention ofthis paragraph is to provide an energy reserve as a safety bufferfor delays to landing. The sUAV is battery operated and the maximum duration offlight from a single battery charge is 12 minutes with a 20%
reserve. Since the aircraftwill neverfly more than 3/4 NM from the point of intended landing, a full batterycharge at launch will ensure that we meet the reserve energy requirement ofthis paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy".
14 CFR 91.203(a) 

### & (b) Civil aircraft: Certifications required. The regulation provides that an airworthiness certificate, with the registration numberassigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides thatthe airworthiness certificate be "displayed atthe cabin orcockpit entrance so that it is legible to passengers orcrew." At a maximum gross weight of6.5 pounds, the sUAS is too small to carry documentation, does not have an entrance, and is not capable ofcarrying passengers orcrew. To obtain an equivalent level ofsafety and meetthe intent of91.203, we propose that documents deemed appropriate forthis aircraft by the FAA will be with the crew at the ground control station and available for inspection upon request. In order to identifythe aircraft, we propose thatthe information found on airworthiness and registration certificates be permanently affixed to the aircraftvia placard containing the followinginformation plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23.14 CFR Subpart E(91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations The regulation providesthatthe operator is primarily responsible for maintainingthe aircraft in an airworthycondition, includingcompliance with part 39 and 43. Paragraphs 91.407 and 91.409 require thatthe aircraft be "approved for return to service by a person authorized under43.7" aftermaintenance and inspection. It is our intentionthatthe PIC perform maintenance and inspection ofthe aircraft and "be authorized to approve the aircraftfor returnto service." The PIC will ensure thatthe aircraft is in an airworthy condition priorto every flight and in addition conduct detailed inspections aftereverytwo hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updatingsoftware and firmware forthe on-board computer. All other maintenance will be performed bythe manufacturerortheirdesignated repairfacility. The PIC will documentwork performed in accordance with 91.417. We feel that due to the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level ofsafety. Safetyand Benefits ofthe UAS Coe Aerial 

### & Photography, LLC will be using the UAS in avariety of applications that generally require expensive full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer myriad benefits overthe use offull-sized manned aircraftforelectric power line inspection, oil/gas pipeline inspection, advanced agriculture,film and still photography,just to name a few. Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no passengers orcrew creates a much greater margin ofsafety forthe pilotsand crew. By granting Coe Aerial 

### &Photography, LLC's requested exemptions, the FAA will help drive developmentofsafe and successful commercial UAS operations and will advance the public knowledge base for such operations. Coe Aerial 

### &Photography, LLC is committed to promotingthe UAS research effortsofpolicymakers includingthe FAA, NASA, DOD, and DARPA bysharing data from its commercial UAS operations and serving as a resource forfuture UAS research operations. Thus, the FAA has good
cause to grantthis Petition. Conclusion


### As pointed out in this application, all the sUAS which ourcompany would use, underauthorization by the US DOT-FAA, are small, light-weightdevices operated within the line ofsight (LOS) ofthe Pilot-inCommand (PIC}, less than 400feet above the ground and outside 5 milesfrom any airport, heliport, seaplane base, spaceport, orother location with aviation activities, unlessthe airtrafficcontrol authorities (ATC) have been notified and have authorized each flight within a radius ofthis distance.
All oursUAS have proven capability for controlled flight. They are devices offered forgeneral sale on the market around theworld and have often been used as ModelAircraft inthe USA. We are certain that the studies conducted until now bythe FAA, about Section 332, Public Law 112-95, 2014, have already provided you withthe assurances onthe airworthiness ofsUAS such as ours. For theforegoing reasons, the exemptions requested herein should be granted and Coe Aerial 

### & Photography, lLC should be permitted to conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessary and appropriate by the FAA. The submission of this application and its contents is the best demonstration that indeed it is possible to pursue the authorization process so that some sUAS may be used for legitimate commercial activities and under reasonably safe conditions.

### ing o Coe Aerial 

### & Photography Owner/Pilot