June	28,	2015

U.	S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Ave,	SE	

Washington,	DC	20590

Re:	 Exemption	Request	under	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	

the	Federal	Aviation	Regulations

Dear	Sir	or	Madam:

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

“Reform	Act”)	and	14	C.F.R.	Part	11,	Courage	Inc LLC,	the	operator	of	the	3D	

Robotics	IRIS+	(“sUAS”	or	“IRIS+”),	seeks	an	exemption	from	the	Federal	Aviation	

Regulations	(“FARs”)	listed	below	and	discussed	in	Appendix	A.

The	requested	exemption	would	permit	commercial	operation	of	the	3D	Robotics	

IRIS+,	which	weighs	approximately	4	lbs.	and	is	capable	of	capturing	still	imagery	

and	video.	Applications	for	this	sUAS	include	remote	sensing	with	a	focus	in	

mapping,	real	estate,	insurance	evaluations,	and	industrial	inspection.	Use	of	the	

IRIS+	for	these	purposes	provides	high	quality	data	more	safely	and	at	a	fraction	of	

the	cost	of	using	conventional	aircraft.

Operations	under	the	exemption	will	be	subject	to	strict	operating	requirements	

and	conditions	to	ensure	at	least	an	equivalent	level	of	safety	to	currently	

authorized	operations	using	manned	aircraft.

As	described	more	fully	below,	the	requested	exemption	would	authorize	

commercial	operations	of	remote	sensing	using	the	IRIS+,	which	at	4	lbs.	is	small	in	

size.	The	IRIS+	will	be	operated	under	controlled	conditions	at	low	altitude	in	

airspace	that	is	limited	in	scope,	as	described	more	fully	herein;	it	will	have	

automated	control	features,	as	described	below.	The	IRIS+	also	will	be	operated	by	

an	individual	who	has	at	least	a	private or	sport pilot’s	certification	with	at	least	a	

third	class	medical,	or	U.S.	issued	driver’s license	and	sUAS	flight	training.	Finally,	

the	airspace	in	which	the	sUAS	will	operate	will	be	disclosed	to	the	FAA	in	advance	

through	the	use	of	a	COA	and	NOTAMs.

Courage	Inc. LLC respectfully	submits	that	because	this	small	unmanned	aerial	

vehicle—the	IRIS+—will	be	used	in	lieu	of	comparatively	hazardous operations	now	

conducted	with	fixed	wing	and	rotary	conventional	aircraft,	the	FAA	can	have	

confidence	that	the	operations	will	achieve	at	least	an	equivalent	or	greater	level	of	

safety.	Approval	of	this exemption	would	thereby	enhance	safety	and	fulfill	the	
Secretary	of	Transportation’s	(the	FAA	Administrator’s)	responsibilities	under	

Section	333(c)	of	the	Reform	Act	to	“establish	requirements	for	the	safe	operation	of	

such	aircraft	systems	in	the	national	airspace	system.”

The	name	and	address	of	the	applicant	are:

Courage	Inc. LLC

Address:	625	Manor	Dr.

Reno,	NV	89509

Ph:	(775)	313	5643

Email:	Kirk.Ellern@outlook.com

The	regulations	from	which	the	exemption	is	requested	are	as	follows:

14	C.F.R.	61.113(a)&(b);	

14	C.F.R.	91.7(a);

14	C.F.R.	91.119(c);

14	C.F.R.	91.121;

14	C.F.R.	91.151(a)(1);	

14	C.F.R.	91.405(a);

14	C.F.R.	91.407(a)	(1);	

14	C.F.R.	91.409(a)	(2);	

14	C.F.R.	91.417(a)&(b).

Appendix	A	discusses	each	rule	listed	above	and	explains	why	exemptions	pursuant	

to	the	proposal	set	forth	in	this	letter	are	appropriate,	provide	an	equivalent	level	of	

safety,	and	are	in	the	public	interest.

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

Courage	Inc LLC submits	that	grant	of	this	exemption	application	for	use	of	the	

IRIS+	for	remote	sensing	with a	focus	in	mapping,	real	estate,	insurance	evaluations	

and	industrial	inspection	will	advance	the	Congressional	mandate	in	Section	333	of	

the	Reform	Act	to	accelerate	the	introduction	of	UASs	into	the	national	airspace	

system	(“NAS”)	if	it	can	be	accomplished	safely.	This	law	directs	the	Secretary	of	

Transportation	to	consider	whether	certain	UASs	may	operate	safely	in	the	NAS	

before	completion	of	the	rulemaking	required	under	Section	332	of	the	Reform	Act.	

In	making	this	determination,	the	Secretary	is	required	to	determine	which	types	of	

UASs	do	not	create	a	hazard	to	users	of	the	NAS	or	the	public	or	pose	a	threat	to	

national	security	in	light	of	the	following:

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

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

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

The	grant	of	the	requested	exemption	is	in	the	public	interest	based	on	the	clear	

direction	in	Section	333	of	the	Reform	Act;	the	additional	authority	in	the	Federal	

Aviation	Act,	as amended;	the	strong	equivalent	level	of	safety	surrounding	the	
proposed	operations;	and	the	significant	public	benefit,	including	enhanced	safety	

and	cost	savings	associated	with	transitioning	to	UASs	for	remote	sensing.	

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

exemption	without	delay.

The sUAS

The	IRIS+	complies	with	the	requirements	set	forth	by	Section	333	by	its	small	size,	

weight,	speed,	and	operational	proximity	to	airports	and	densely	populated	areas.	

As	a	result	under	this	exemption	the	IRIS+	is	not	deemed	airworthy	by	an	

airworthiness	certificate,	but	rather	it	is	deemed	airworthy	by	the	operator	

conducting	a	thorough	preflight	of	the	aircraft.	This	aircraft	will	also	be	registered	in	

accordance	to	14	CFR	Part	47,	marked	in	accordance	to	14	CFR	Part	45	Subpart	C,	

and	accompanied	by	a	letter	of	alternative	marking	due	to	the	unconventional	

design	of	a	quadcopter.	Markings	will	be	as	large	as	practicable.	This	aircraft	is	of	

the	same	size,	configuration,	and	operational	capabilities	of	the	aircraft	granted in	

exemptions	11138,	11153, 11157 and	11741.

Aircraft	Make	and	Model:	3D	Robotics	IRIS+	

Configuration:	Quad	copter

Aircraft	Performance/Specifications:

 Ground	Control	Station	(GCS):	The	aircraft	will	be	primarily	controlled	

through	the	use	of	a	typical	2.4	GHz	RC	transmitter.	The	aircraft	can	also	be	

pre- programmed	to	conduct	a	mission	through	the	use	of	a	laptop	or	tablet	

via	a	915	MHz	telemetry	link.	Whenever	operations	are	conducted	in	this	

matter,	the	RC	Transmitter	will	be	able	to	take	control	of	the	aircraft	if	the	

need	arises.	

 Video	Downlink:	5.8	GHz	at	200mW	

 Lost	Com:	Aircraft	will	autonomously	return	to the	launch	location	and	safely	

land.	

 Emergency	Procedure:	Should	the	need	arise	the	aircraft	can	be	commanded	

by	a	switch	on	the	RC	transmitter	to	safely	land	immediately	or	return	and	

land	at	the	launch	location.	

 Power	Supply:	3S	5.1Ah	8C	Lithium	Polymer	Battery	

 Dimensions:	550mm	motor	to	motor	

 Maximum	Speed:	44	knots	

 Normal	operating	speed:	Less	than	30	knots	

 Weight	without	payload:	1282g	(2lb	13oz)	

 Weight with	payload:	1656g	(3lb	10oz)

Aircraft	manuals	and	operations	checklist	will	be	included	as	additional	information	

to	this	petition	for	exemption.	
Operator Requirements

To	operate	the	sUAS	under	this	exemption	an	operator	will	be	required	to	have	at	

least	a	sports	pilot’s	certification,	and	aircraft	specific	flight	training	as	defined	

below.

Aircraft	specific	flight	training	to	include:

25	hours	as	a	UAS	rotorcraft	pilot	including

10	hours	logged	as	a	UAS	pilot	with	a	multi-rotor	UAS

5	hours	with	the	specific	make	and	model	of	the	UAS,	and

At	least	3	take-offs	and	landings	within	the	preceding	90	days

Mandatory Operating Conditions

Grant	of	the	exemption	to	Courage	Inc LLC will	be	subject	to	the	following	

mandatory	conditions	for	flight	operations.

 Operations	shall	not	occur	over	congested,	actively,	or	densely	populated	

areas	as	defined	by	the	local	FSDO.	

 Permission	from	landowner is	required	before	commencing	any	flight.	

 Operations	will	only	occur	during	Visual	Flight	Rules	Meteorological	

Conditions	(VMC).	

 Operations	will	not	occur	less	than	500	feet	below	or	less	than	2,000	feet	

horizontally	from	a	cloud	or	when	visibility	is	less	than	3	statute	miles	from	

the	operator.	

 The	sUAS	will	remain	clear	of	manned	aircraft	and	yield	right	of	way.	

 A	flight	test	will	be	conducted	after	any	major	repair	or	alteration.	

 A	preflight	check	will	be	conducted	before	each	flight	to	assure	airworthiness.	

 Aircraft	will	remain	within	Visual	Line	of	Sight	(VLOS)	of	the	operator.	

 All	operations	will	be	conducted	with	a	Visual	Observer	(VO).	

 Operations	will	be	limited	to	daylight	hours.	

 Operations	will	be	concluded	with	no	less	than	25%	battery	power	

remaining.	

 Operations	will	not	exceed	400ft	AGL.	

 Operations	will	not	occur	within	5nm	of	any	airport	unless	a	letter	of	

agreement	with	that	airport’s	management	is	obtained.	

 Operations	will	take	place	under	a	COA.	

 Operator	will	file	a	NOTAM	for	each	flight.	

 All	required	permissions	and	permits	will	be	obtained	from	territorial,	state,	

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

appropriate	governmental	agencies.	

 All	non-participants	will	keep	500ft	away	from	operations	unless	there	are	

adequate	barriers	to	protect	them.	

 All	operations	will	be	conducted	according	to	the	manufacturer’s	manuals.	

 All	documents	that	will	be	kept	at	the	GCS	include	but	are	not	limited	to;	the	

aircraft	manuals,	maintenance	logs,	aircraft	registration,	grant	of	exemption,	

and	COA.
Public Interest

Consistent	with	the	requirements	of	14	C.F.R.	§11.81(d),	Petitioner	offers	the	

following	reasons	why	granting	this	petition	for	exemption	is	in	the	public	interest,	

i.e.,	how	granting	it	would	benefit	the	public	as	a	whole.

Approval	of	this	exemption	allowing	commercial	operations	of	sUAS	in	the	mapping,	

real	estate,	insurance	evaluation,	and	industrial	inspection	industries	benefits	the	

public	as	a	whole	in	the	following	ways:

 It	helps	fulfill	Congress'	goal	in	passing	Section	333(a)	through	(c)	of	the	

Reform	Act,	namely,	the	FAA	Administrator's	assessment	of	whether	certain	

UAS	may	operate	safely	in	the	National	Airspace	System	before	completion	of	

the	rulemaking	required	under	Section	332	of	the	Reform	Act.	

 The	operation	significantly	improves	safety	and	reduces	risk	by	alleviating	

human	exposure	to	danger	associated	with	current	aerial	remote	sensing	

methods,	namely,	full	size	helicopters.	Reducing	human	exposure	to	death	or	

serious	injury	associated	with	manned	aircraft	performing	these	tasks	

furthers	the	public’s	interest.	

 Petitioner's	sUASs	are	battery	powered	and	create	no	emissions.	If	

Petitioner's	sUAS	crashes,	there	is	no	fuel	to	ignite	and	explode.	Any	impact	

of	Petitioner's	lightweight	sUASs	is	far	less	than	a	full	size	manned	aircraft.	

The	public's	interest	is	furthered	by	minimizing	ecological	impact	of	an	

accident	and	by	reducing	human	exposure	to	potentially	harmful	emissions	

associated	with	manned	aircraft.	

 Remote	sensing	is	as	valuable	tool	for	mapping,	real	estate,	insurance	

evaluations,	and	industrial	inspection.	However,	problems	with	safety,	cost,	

statistical	integrity,	and	logistics	continue	to	impede	remote	sensing	from	

conventional	manned	aircraft.	The	use	of	sUAS	addresses	these	problems	and	

is	a	powerful	tool	for	performing	a	wide-range	of	remote	sensing	

applications.	The	public	as	a	whole	will	benefit	from	the	safer	and	more	costeffective	remote	sensing	services	that	sUAS	operations	provide.	

Privacy

All	flights	will	occur	over	property	with	the	landowner’s	prior	consent.	

Conclusion

Courage	Inc. LLC seeks	an	exemption	from	the	FARs	set	forth	above	and	in	Appendix	

A	to	allow	commercial	operations	of a	sUAS	conducting	remote	sensing	with	a	focus	

in	agriculture,	real	estate,	insurance	evaluations	and	industrial	inspection.
Approval	of	this	exemption	allowing	commercial	operations	of	the	IRIS+	for	remote	

sensing	will	enhance	safety	by	reducing	risk.	Conventional	remote	sensing	

operations,	using	turbine	or	piston-powered	aircraft	present	risks	associated	with	

vehicles	that	can	weigh	5,000	to	7,000	lbs.,	or	more,	carry	large	quantities	of	fuel,	

passengers,	and,	in	some	cases,	cargo.	In	contrast,	an	IRIS+	weighing	less	than	4	lbs.	

and	powered	by	batteries	eliminates	a	portion	of	that	risk	given	the	reduced	mass	

and	lack	of	combustible	fuel	carried	on	board.	The	IRIS+	will	carry	no	passengers	or	

crew	and,	therefore,	will	not	expose	any	individuals	to	the	risks	associated	with	

manned	aircraft	flights.

Additionally,	no	national	security	issue	is	raised	by	the	grant	of	the	requested	

exemptions	due	to	all	pilots	being	certified	through	the	FAA.

The	operation	of	the	IRIS+,	weighing	less	than	4	lbs.,	for	remote	sensing	in	

accordance	with	the	strict	conditions	outlined	above,	will	provide	an	equivalent	

level	of	safety	supporting	the	grant	of	the	exemptions	requested	herein.

The	IRIS+’s	satisfaction	of	the	criteria	set	forth	in	Section	333	of	the	Reform	Act—

size,	weight,	speed,	operating	capabilities,	lack	of	proximity	to	airports	and	

populated	areas,	operation	within	visual	line	of	sight,	and	national	security—and	its	

showing	of	an	equivalent	level	of	safety	provides	more	than	adequate	justification	

for	the	grant	of	the	requested	exemptions	allowing	commercial	operation	of	the	

IRIS+	in	the	remote	sensing	business.

Sincerely,

Kirk	Ellern

Managing	Member,	Courage	Inc. LLC
APPENDIX A:

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS

UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

Courage	Inc LLC requests	an	exemption	from	the	following	regulations,	all	of	which	

have	been	granted	by	every	approved	Section	333	exemption	at	the	time	of	this	

submission.

14	C.F.R.	§	61.113	Private or	Sport pilot	privileges	and	limitations:	Pilot	in	command.

The	regulation	provides	that	no	person	that	holds	a	private or	sport pilot	certificate	

may	act	as	pilot	in	command	of	an	aircraft	for	compensation	or	hire.	Subparagraph	

(b)	allows	a	private or	sport pilot	to	act	as	pilot	in	command	of	an	aircraft	in	

connection	with	any	business	or	employment	if:	(1)	The	flight	is	only	incidental	to	

that	business	or	employment;	and	(2)	The	aircraft	does	not	carry	passengers	or	

property	for	compensation	or	hire.

Equivalent	Level	of	Safety

Currently,	there	are	no	applicable	areas	identified	for	sUAS	in	either	the	private	or

commercial	sector	and	therefore	an	exemption	is	required	to	conduct	commercial	

operations.	As	flight	operations	will	be	conducted	in	a	restricted	environment	as	

described in	the	operations	section,	these	strict	guidelines	will	achieve	an	

equivalent	level	of	safety	for	each	individual	flight	especially	when	compared	to	

commercial	flights	identified	in	Part	61	when	originally	developed.

14	C.F.R.	§	91.7(a):	Civil	Aircraft	Airworthiness

Petitioner	seeks	an	exemption	from	14	C.F.R.	§	91.7(a),	which	requires	that	a	civil	

aircraft	be	in	airworthy	condition	to	be	operated.	Inasmuch	there	will	be	no	

airworthiness	certificate	issued	for	the	sUAS,	should	this	exemption	be	granted,	no	

FAA	regulatory	standard	will	exist	for	determining	airworthiness.

Equivalent	Level	of	Safety

Given	the	size	of	the	IRIS+	and	the	preflight	procedures	including	the	review	of

maintenance	logs	and	preflight	check	lists,	an	equivalent	level	of	safety	will be	

provided	to	assure	the	aircraft	is	in	an	airworthy	condition.

14	C.F.R.	§	91.119(c):	Minimum	Safe	Altitudes

Petitioner	requests	an	exemption	from	the	minimum	safe	altitude	requirements	of	

14	C.F.R.	§	91.119(c)	which	states	that	aircraft	may	not	operate	closer	than	500	feet	

above	the	surface	and	away	from	any	person,	vessel,	vehicle,	or	structure	in	noncongested	areas.

To	provide	the	intended	operations,	the	sUAS	is	operated	below	400	feet	AGL.
Equivalent	Level	of	Safety

Compared	to	flight	operations	with	rotorcraft	weighing	far	more	than	the	4	pounds

proposed	herein,	and	given	the	lack	of	flammable	fuel,	any	risk	associated	with	

these	operations	is	far	less	than	those	that	presently	exist	with	conventional	aircraft.	

An	equivalent	level	of	safety	will	be	achieved	given	the	size,	weight,	and	speed	of	the	

UAS,	as	well	as	the	location	where	it	is	operated.	As	set	forth	in	the	operations	

section	of	this	exemption,	the	sUAS	will	be	operated	away	from	densely	populated	

areas	and	at	least	5nm	away	from	airports	(unless	a	letter	of	agreement	from	the	

airport’s	management	is	obtained),	where	buildings	and	people	will	not	be	exposed	

to	operations	without	their	pre-obtained	consent.	Because	of	the	advance	notice	to	

the	property	owners	and	participants,	all	affected	individuals	will	be	well	aware	of	

the	planned	flight	operations.

14	C.F.R.	§	91.121:	Altimeter	Settings

This	petition	seeks	an	exemption	from	14	C.F.R.	§	91.121,	which	requires	a	person	

operating	an	aircraft	to	maintain	cruising	altitude	or	flight	level	by	reference	to	an	

altimeter	that	is	set	to	the	elevation	of	the	departure	airport	or	barometric	pressure.	

An	exemption	is	required	because	the	sUAS	does	not	have	a	barometric	altimeter,	

but	rather	a	GPS	altitude	read	out.

Equivalent	Level	of	Safety

An equivalent	level	of	safety	will	be	achieved	by	the	operator	confirming	the	altitude	

of the	launch	site	shown	on	the	GPS	altitude	indicator	before	flight.	Moreover,	the	

PIC	will	use	the	GPS	altitude	indicator	to	constantly	monitor	the	sUAS's	height,	thus	

ensuring	operation	at	safe	altitudes.

14	C.F.R.	§	91.151(a)(1):	Fuel	Requirements	for	Flight	in	VFR	Conditions

Petitioner	requests	an	exemption	from	14	C.F.R.	§	91.151(a)(1)'s	fuel	requirements	

for	flight	in	VFR	conditions	during	the	day.	Section	91.151(a)(1)	states:

(a)	No	person	may	begin	a	flight	in	an	airplane	under	VFR	conditions	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	–

(1)	During	the	day,	to	fly	after	that	for	at	least	30	minutes;

Here,	the	battery	powering	the	IRIS+	provides	approximately	16	minutes	of	flight.	

To	meet	the	30	minutes	reserve	requirement	in	14	C.F.R.	§	91.151,	sUAS	flights	

could	not	be	conducted.	Given	the	limitations	on	the	sUAS's	proposed	flight	area	and	

the	location	of	its	proposed	operations	within	a	predetermined	area,	a	safety	margin	

based	on	a	reserve	amount	of	battery	life	is	needed.

Equivalent	Level	of	Safety

An	equivalent	level	of	safety	will	be	achieved	because	the	operations	will	be	

conducted on-site	without	significant	transit	time	by	the	sUAS.	All	flights	will	be	

planned	to	be	terminated	with	no	less	than	25%	reserve	battery	power	still	
available.	This	restriction	would	be	more	than	adequate	to	return	the	sUAS	safely	to	

the	ground	and	its	planned	landing	zone	from	anywhere	in	its	limited	operating	area	

even	in	the	event	of	an	unexpected	occurrence.	Operation	of	the	sUAS	with	less	than	

30	minutes	of	reserve	fuel	does	not	include	the	type	of	risks	that	Section	

91.151(a)(1)	was	intended	to	alleviate	given	the	size	and	speed	of	the	small	UAS,	

and	the	proximity	of	the	flight	operation	to	the	landing	zone.

14	C.F.R.	§	91.405(a),	91.407(a)(1),	91.409(a)(2);	91.417(a)	and	(b):	Maintenance	

Inspections

Petitioner	also	seeks	an	exemption	from	the	maintenance	inspection	requirements	

contained	in	14	C.F.R.	§	91.405(a),	91.407(a)(1),	91.409(a)(2);	91.417(a)	and	(b).	

These	regulations	specify	maintenance	and	inspection	standards	in	reference	to	14	

C.F.R.	Part	43.	See, e.g.,	14	C.F.R.	§	91.405(a)	(stating	that	each	owner	or	operator	of	

an	aircraft	"[s]hall	have	the	aircraft	inspected	as	prescribed	in	subpart	E	of	this	part	

and	shall	between	required	inspections	...have	discrepancies	repaired	as	prescribed	

in	part	43	of	this	chapter").	An	exemption	to	these	regulations	is	needed	because	

Part	43	and	these	sections	only	apply	to	aircraft	with	an	airworthiness	certificate,	

which	the	sUAS	will	not	have.

Equivalent	Level	of	Safety

An	equivalent	level	of	safety	will	be	achieved	because	the	operator	will	ensure	that	

the sUAS	is	in	working	order	prior	to	initiating	flight	by	following	the	preflight	

checklist,	perform	required	maintenance,	and	keep	a	log	of	any	maintenance	

performed.	The	operator	is	the	person	most	familiar	with	the	aircraft	and	best	

suited	to	maintain	the	aircraft	in	an	airworthy	condition.
APPENDIX B:

SUMMARY OF Courage Inc LLC SECTION 333 EXEMPTION

REQUEST

Courage	Inc. LLC hereby	provides	pursuant	to	Part	11	a	summary	of	its	exemption	

application	to	allow	commercial	operation	of	the	IRIS+	unmanned	aircraft	in	remote	

sensing.	An	exemption	is	requested	from	the	following	regulations:

14	C.F.R.	61.113(a)&(b);	

14	C.F.R.	91.7(a);

14	C.F.R.	91.119(c);

14	C.F.R.	91.121;

14	C.F.R.	91.151(a)(1);	

14	C.F.R.	91.405(a);

14	C.F.R.	91.407(a)	(1);	

14	C.F.R.	91.409(a)	(2);	

14	C.F.R.	91.417(a)&(b).