11/2/15 

James R. Cobb 

9001 Hickman Road, Suite 350 

Urbandale, Iowa 50322 

icobb007@mchsi.com Website: jamesrcobbphoto.com 

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

and 14 CFR Part 11, James R. Cobb, operator of Unmanned Aircraft Systems (UAS), hereby 

applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow 

commercial operation of the designated UAS, provided such operations are conducted within 

and under the conditions outlined herein or as may be established by the FAA as required by 

Section 333. 

1. Petitioner 

James R. Cobb began his photography business in 1977. The business specializes in all areas 

of photography as well as video. Activities include corporate portraits, aerial photography, 

weddings, and family portraits as well as various other commercial photography assignments. 

2. Section 333 

Mr. Cobb's petition is consistent with Congress's goal set forth in Section 333 of the FMRA, 

which directs the Secretary of Transportation to consider whether certain UAS may operate 

safely in the national airspace system ("NAS") before completion of the rulemakings required 

under Section 332 of that legislation. In making this determination, the Secretary is required to 

determine which types of UAS 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: (1) the UAS' size, weight, speed, and 

operational capability; (2) operation of the UAS in close proximity to airports and populated 

areas; and (3) operation of the UAS within visual line of sight of the operator. To implement 

Section 333, FAA has the authority to issue exemptions from its safety regulations and minimum 

standards when the Administrator decides a requested exemption is in the public interest. 

Mr. Cobb's proposed UAS operations meet the requirements of, and qualify for expedited 

approval under, Section 333. Mr. Cobb's Phantom 3 Advanced UAS weigh less than 55 pounds, 

will operate at less than 400 feet above ground level ("AGL"), within visual line of sight 

("VLOS"), at speeds of no more than 87 knots, and will generally comply with the same 

conditions and limitations FAA established in issuing previous Section 333 grants. 

Operations conducted under these safeguards will provide at least an equivalent level of 

safety compared to the current regulatory structure. Moreover, Mr. Cobb's operations will not 

"create a hazard to users of the national airspace system or the public or pose a threat to 

national security" due to the size of the UAS and the restricted areas in which they will operate. 
III. Regulations from Which an Exemption is Requested 

Mr. Cobb request an exemption from the following regulations to the extent necessary to 

conduct the operations described in the petition. 

• 14 CFR 45.23(b) 

• 14 CFR 91.103 

• 14 CFR 91.109 

• 14 C.F.R. §§ 61.23(a) and (c) 

• 14 C.F.R. §§ 61.101(e)(4) and (5) 

• 14 C.F.R. § 61.113(a) 

• 14 C.F.R. § 61.315(a) 

• 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)(1) and (2) 

• 14 C.F.R. §§ 91.417(a) and (b) 

Commercial operation of an UAS, as described herein, which is equipped with camera(s) 

and sensors, would provide professional services in the following areas: 

1. Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities. 

2. Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority. 

3. Aerial video and/or photography for public and/or private use including television, public 

events, and newsgathering. 

4. Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities or 

government has requested it by contract or donation. 

5. Training to persons individually or belonging to both private and/or public organizations to 

increase awareness and improve safety for current and future UAS operations within the 

NAS. 

1111. Unmanned Aircraft System 

Operations will be conducted using a Phantom 3 Advanced and a transportable ground 

station. The Phantom 3 Advanced is referred to as a quad-copter with a maximum gross weight 

of about 3 pounds. It is equipped with four rotors that are driven by electric motors powered by 

batteries. The UA has a maximum airspeed of 35 mph. 

Also, given the small size of the UAS's involved and the restricted controlled environment 

within which they will operate, the applicant fits within that zone of safety (an equivalent level of 
safety) in which Congress envisioned that the FAA must, by exemption, allow commercial 

operations of UASs to commence immediately. Also due to the size of the UASs and the 

controlled areas in which the relevant UASs will operate, approval of the application presents no 

national security issue. Given the following, the grant of the requested exemptions is clearly in 

the public interest. James R. Cobb proposes that the exemption requested herein apply to civil 

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

limitations provide for an exceptional level of safety to operations. These limitations and 

conditions to which James R. Cobb agrees to be bound when conducting commercial 

operations under an FAA issued exemption including: 

V. Unmanned Aircraft PIC 

The PIC will be a FAA licensed airman with either an airline transport, commercial, private, 

recreational, or sport pilot certificate, holding a current FAA airman medical certificate or a valid 

U.S. driver's license. The PIC will also meet the flight review requirements specified in Section 

61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. Prior to conducting 

commercial operations under this exemption, the PIC will have accumulated and logged 

sufficient UAS-specific flight experience on the aircraft to be used. 

VI. Operation of the Unmanned Aircraft 

1. The UAS will weigh less than 55 lbs. 

2. The UAS will not be flown at a ground speed exceeding 87 knots (i.e. 100 miles per hour). 

3. Flights will be operated within line of sight of operator at all times. 

4. Flights will be terminated at 15% battery power reserve. 

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

6. UAS operators will be trained and certified in the proper safety and operations of the UAS. 

7. If the UAS loses communications or loses its GPS signal, the UAS will have capability to 

return to a pre-determined location within the Security Perimeter and land. 

VII. Conclusion 

Accordingly, Mr. Cobb respectfully requests that the FAA grant the requested exemption and 

is prepared to modify or amend any part of this request to satisfy the need for an equivalent 

level of safety. We look forward to working with your office. Please contact us at any time if 

additional information or clarifications are needed. 

Sincerely, 

James R. Cobb 

James R. Cobb Photography