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 ofsafety) 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