March 8, 2016

Attn:

U. S. Department of Transportation Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave, SE Washington, DC 20590

RE: Phillip M Cochran

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF 

THE CODE OF FEDERAL REGULATIONS 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) CONCERNING COMMERCIAL OPERATION OF DJI Phantom 4

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE 

FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Phillip M Cochran

790971 S. 3340 Rd.

Perkins, OK 74059

580-747-8161

phillipmcochran@gmail.com

SUMMARY

Phillip M Cochran seeks 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), to operate an Unmanned Aircraft System (DJI 

Phantom 4) pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012 (FMRA). This exemption will permit Phillip Cochran to operate an 

Unmanned Aircraft System (UAS) for the commercial purpose of conducting 

aerial video and photography of construction sites, residential and commercial 

real estate, civil landscapes and events over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Phillip Cochran is a retired Air Force officer and Command Pilot with over 2600 

hours of flight time in high speed high performance aircraft including the F-16 and 

T-38 with much of this time as Flight Instructor. Furthermore, Phillip Cochran 

holds civilian pilot ratings as Airline Transport Pilot, Multi Engine Land, Single 

Engine Land and Glider Pilot. The objective of Phillip Cochran and my

Unmanned Aircraft System (DJI Phantom 4) aerial operations is to provide a 

more affordable, high-quality production system for a variety of governmental, 

commercial, public, and residential uses, specifically targeting:

• Construction sites before and after

• Appraisals

• Real-estate marketing

• Economic development
• Civic landmarks

• Special event coverage

• Private and governmental training

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 4, UAS

Phillip Cochran seeks an exemption to operate DJI Phantom 4 system for 

compensation or hire within the NAS. The DJI Phantom 4 is vertical takeoff and 

landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) 

utilizing electronic tablet or smart phone systems. The DJI Phantom 4 

specifications can be found here: http://www.dji.com/product/phantom-4/info. 

The DJI Phantom 4 that will be operated by Phillip Cochran 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.

BASIS FOR PETITION

Petitioner, Phillip Cochran, pursuant to the 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, hereby petitions the Administrator to commercially operate the DJI 

Phantom 4, UAS in the National Airspace System (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, Phillip Cochran’s operation of DJI 

Phantom 4 UAS meets 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. Accordingly, PHILLIP COCHRAN requests 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 apply to aircraft with an 

airworthiness certificate.

PHILLIP COCHRAN submits that the requested relief is proper since an 

equivalent level of safety will be ensured. PHILLIP COCHRAN will use 

experienced personnel or technicians to perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and 

practices prescribed in the operating documents Furthermore, PHILLIP 

COCHRAN will document and maintain all maintenance records for the DJI 

Phantom 4 UAS. 
Relief from certain requirements of Section 61.113(a) and (b), entitled Private 

pilot privileges and limitations: Pilot in command, is requested by The PHILLIP 

COCHRAN to the extent necessary to allow a Pilot in Command (PIC) holding a 

private pilot or higher level certificate, as well as an airman medical certificate, 

and who has demonstrated, by meeting minimum flight- hour and currency 

requirements, that the PIC is able to safely operate the DJI Phantom UAS in a 

manner consistent with this exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles 

and structures.

PHILLIP COCHRAN seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Phantom 4 UAS do not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, PHILLIP 

COCHRAN submits that I will ensure that the DJI Phantom 4 UAS is in an 

airworthy condition, prior to every flight, by determining that the UAS are in 

compliance with the operating documents and that the aircraft are in a condition 

for safe flight.

PHILLIP COCHRAN also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Phantom 4 UAS will not have a 

typical barometric altimeter onboard. However, altitude information of the DJI 

Phantom 4 UAS will be provided to the PIC via Global Positioning System (GPS) 

equipment and radio communications telemetry data link, which downlinks from 

the UA to the GCS for active monitoring of the flight path. This altitude 

information, combined with PHILLIP COCHRAN’s operation of the DJI Phantom 

4 UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of 

safety equivalent to Section 91.121.

Additionally, PHILLIP COCHRAN seeks an exemption from the requirements of 

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. 

PHILLIP COCHRAN submits that safety will not be affected by operation of the 

DJI Phantom 4 UAS during daylight hours in visual meteorological conditions 

(VMC) under visual flight rules (VFR), with enough battery power to fly for a total 

duration of approximately 23 minutes. Battery power indicators are also able to 

show exactly how much battery power is left, as well as how much time is 

needed to return safely back to point of take off.

In accordance with 14 C.F.R. § 11.81, PHILLIP COCHRAN provides the 

following information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

Phillip Cochran

790971 S. 3340 Rd.

Perkins, OK 74059
580-747-8161

phillipmcochran@gmail.com

B. The Specific Sections Of 14 C.F.R. From Which The PHILLIP COCHRAN

Seeks Exemption.

1. PHILLIP COCHRAN Seeks Exemption From The Requirements Of Section 

61.113(a) And (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 

(PIC) of an aircraft that is carrying passengers or property 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 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.

2. PHILLIP COCHRAN Seeks 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. PHILLIP COCHRAN Seeks 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, by reference to an altimeter that is set, 

when operating--(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. PHILLIP COCHRAN Seeks 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 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, to fly 

after that for at least 20 minutes.

5. PHILLIP COCHRAN Seeks Exemption From The Requirement Of Section 

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. PHILLIP COCHRAN Seeks Exemption From The Requirements Of Section 

91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive 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 service by a person authorized under § 

43.7 of this chapter[.]

7. PHILLIP COCHRAN Seeks Exemption From The Requirements Of Sections 

91.409(a)(1) And 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 by 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. PHILLIP COCHRAN Seeks Exemption From The Requirements Of Sections 

91.417(a) And 91.417(b). 

Section 91.417, entitled Maintenance 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 section:

(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, propeller, 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 certificate 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 life-limited parts of each airframe, engine, propeller, 

rotor, and appliance.

(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 each, 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 by § 43.9(d) of this chapter for each major 

alteration to the airframe and currently 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 this section shall be retained until 

the work is repeated or superseded by other work or for 1 year 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 the 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 PHILLIP COCHRAN Seeks And The Reason PHILLIP 

COCHRAN Seeks The Relief.

1. Extent Of Relief PHILLIP COCHRAN Seeks And The Reason PHILLIP 

COCHRAN Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and 

limitations: Pilot in command, is requested to the extent necessary to allow a PIC 

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. 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 PIC 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.

As set forth more fully below, PHILLIP COCHRAN submits that an equivalent 

level of safety will be maintained because no PIC will be allowed to operate the 

DJI Phantom 4 UAS unless that PIC has met certain flight-hour and currency 

requirements, demonstrating that the PIC is able to safely operate either the DJI 

Phantom 4 UAS in a manner consistent with the operations specifications as 

described in this exemption, including evasive and emergency maneuvers, as 

well as maintaining appropriate distances from people, vessels, vehicles and 

structures. Further, PHILLIP COCHRAN submits that all flights of the DJI 

Phantom 4 UAS, conducted by the PIC pursuant to the grant of this Petition: (1) 

will be incidental to PHILLIP COCHRAN’s business; and (2) will not carry 

passengers or property for compensation or hire.

2. Extent Of Relief PHILLIP COCHRAN Seeks And The Reason The PHILLIP 

COCHRAN Seeks Relief From Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow PHILLIP COCHRAN to determine that the DJI Phantom 

4 UAS are in airworthy condition prior to every flight by ensuring that the UAS is 

in compliance with the operating documents. PHILLIP COCHRAN seeks the 

requested relief because the DJI Phantom 4 UAS do not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, PHILLIP 

COCHRAN will ensure that the DJI Phantom 4 UAS are in airworthy condition 

based upon its compliance with the operating documents prior to every flight, and 

further, determine that the aircraft are in condition for safe flight, as stated in the 

conditions and limitations below.

3. Extent Of Relief PHILLIP COCHRAN Seeks And The Reason PHILLIP 

COCHRAN Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow 

flight operations of the DJI Phantom 4 UAS, which utilize a barometric pressure 

sensor, GPS equipment, and a radio communications telemetry data link to 

downlink altitude information from the UA to the PIC at the ground control station 

(GCS). Since the FAA requires that any altitude information concerning UAS 

operations be reported to air traffic control (ATC) in feet above ground level 

(AGL), PHILLIP COCHRAN seeks the requested relief because the DJI Phantom 

4 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 fully set forth herein, an equivalent level of safety will be 

maintained since the DJI Phantom 4 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 PIC 

with altitude information of the UA on the heads-up display of the GCS.

4. Extent Of Relief PHILLIP COCHRAN Seeks And The Reason PHILLIP 

COCHRAN Seeks 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 DJI Phantom 4 UAS during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), for a total duration of 23 

minutes. PHILLIP COCHRAN seeks the requested relief because without an 

exemption from Section 91.151(b), the flight time duration of the battery powered 

DJI Phantom 4 UAS will severely constrain the practicality of any aerial video or 

still photo flight operations that PHILLIP COCHRAN proposes to conduct 

pursuant to this Petition. Significantly, as set forth below, the technical 

specifications of the DJI Phantom 4 UAS, the DJI Phantom 4 operating 

documents, and PHILLIP COCHRAN’s proposed operating limitations, ensure 

that PHILLIP COCHRAN will safely operate the battery powered DJI Phantom 4

UAS during daylight hours in visual meteorological conditions (VMC), under 

visual flight rules (VFR), with enough battery power to fly for a total duration of 23 

minutes.

5. Extent Of Relief PHILLIP COCHRAN Seeks And The Reason PHILLIP 

COCHRAN Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), And 91.417(a) & (b). Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) 

& (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness 

certificate, 

PHILLIP COCHRAN requests relief from these Sections because the DJI 

Phantom 4 UAS do not require airworthiness certificates. As set forth more fully 

below, the DJI Phantom 4 UAS meet the conditions of FMRA Section 333 for 

operation without an airworthiness certificate. Accordingly, PHILLIP COCHRAN

will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UAS using the methods, techniques, and practices 

prescribed in the UAS operating documents. Furthermore, PHILLIP COCHRAN

will document and maintain all maintenance records for the DJI Phantom 4 UAS.

D. The Reasons Why Granting PHILLIP COCHRAN Request Would Be In The 

Public Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing PHILLIP 

COCHRAN to safely, efficiently, and economically perform aerial video and 

photography of construction sites, real estate, events and civic landscape over 

certain areas of the United States. Additionally, use of the DJI Phantom 4 UAS 

will decrease congestion of the NAS, reduce pollution, and provide significant 
benefits to the economy. Notably, the benefits of PHILLIP COCHRAN’s proposed 

operation of the DJI Phantom 4 UAS will be realized without implicating any 

privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Phantom 4 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 DJI Phantom 4 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, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be 

reduced. The DJI Phantom 4 UAS do not require an airport to takeoff or land. 

Likewise, a reduction of manned aircraft 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 Safety And Efficiency Of The DJI Phantom 4

UAS.

Conducting aerial acquisitions with the DJI Phantom 4 UAS, instead of manned 

aircraft, will greatly 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 DJI Phantom 4

UAS produce no air pollution, and is the most viable environmentally conscious 

alternative to the cabin class, six cylinder internal combustion engine aircraft that 

are typically utilized for aerial video and photography, while burning 

approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 4

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 DJI Phantom 4 UAS to perform aerial acquisitions, the substantial 

risk to life and property in the air and on the ground, which is usually associated 

with traditional manned aircraft flight operations, will be substantially reduced or 

completely eliminated. Aside from the lack of flight crew members located 

onboard the aircraft, the DJI Phantom 4 UAS (weighing approximately 2.8 

pounds at their maximum gross weight with diagonal dimension of 23.2 inches, 

and with no fuel on board), has less physical potential for collateral damage to 

life and property on the ground, and in the air, compared to the manned aircraft 

that typically 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 The DJI Phantom 4

UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 4 UAS are also an 

economical alternative to using manned aircraft to conduct similar aerial 

operations. As such, operation of the DJI Phantom 4 UAS will allow United 

States based companies to remain competitive and contribute to growth of the 

U.S. economy. Specifically, with the rising cost of aviation fuel and the 

Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded 

aviation fuels, U.S. owned and operated companies must adopt new and 

alternative technology in order to remain competitive. Operating the battery 

powered DJI Phantom 4 UAS is one such technology that not only allows 

companies greater operational flexibility compared to manned aircraft, but 

provides such flexibility without the high operational cost of a traditional manned 

aircraft.

By operating the DJI Phantom 4 UAS, companies can remain competitive and 

profitable, and therefore, provide greater job stability to employees and 

contractors, which will ultimately contribute to growth of the U.S. economy. 

Improved financial performance of U.S. companies, through commercial use of 

the DJI Phantom 4 UAS, provides a stable workforce that increases 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 Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been 

conducted for decades, PHILLIP COCHRAN’s proposed operation of the DJI 

Phantom 4 UAS will not implicate any privacy issues. Specifically, the DJI 

Phantom 4 UAS will be operated only in compliance with property owner 

involvement as well as local law enforcement notification, and in accordance with 

the Federal Aviation Regulations, including the minimum altitude requirements of 

14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect 

Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal 

To That Provided By The Rule From Which PHILLIP COCHRAN Seeks 

Exemption.

1. Reasons Why The DJI Phantom 4 UAS Meet The Conditions Of The FAA 

Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated 
with the unmanned aircraft and its operation, PHILLIP COCHRAN’s operation of 

the DJI Phantom 4 UAS 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. Specifically, 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 aircraft systems may operate 

safely in the national 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), the 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 States 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 national 

airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace system.

In seeking this exemption, The PHILLIP COCHRAN submits that the DJI 

Phantom 4 UAS can operate safely in the NAS pursuant to FMRA Section 333, 

as demonstrated by: 

i. The DJI Phantom 4 UAS does 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.

ii. The DJI Phantom 4 UAS Global Positioning Modes Enable The UAS To 

Remain Within A Defined Operational Area. The DJI Phantom 4 UAS may be 

operated in both manual and global positioning flight modes. A complete 

description of the flight and navigational modes of the DJI Phantom 4 UAS is 

provided at pages 11 of the DJI Phantom 4 User Manual attached hereto as 

Appendix A.

iii. The DJI Phantom 4 UAS Are Designed For Automatic Return To Home Point 

Or Hover In The Event Of Loss Of The Control Link Or Navigation. When the 

Control Link is lost, the DJI Phantom 4 UAS will remain stationary, in flight, for 3 

seconds or more. If, after 3 seconds, the DJI Phantom 4 UAS does not reacquire 

control link data from the GCS, the UAS will assume that the Control Link is lost 
and the will return to the home position (i.e., failsafe mode) via GPS, and will 

descend to the takeoff position and shutdown. A complete description of the 

Failsafe Functions of the DJI Phantom 4 UAS are set forth at pages 12 through 

14 of the DJI Phantom 4 User Manual, attached hereto as Appendix A.

iv. The DJI Phantom 4 GCS And Its Operation. Flight Operations Of DJI 

Phantom 4 UAS Is Limited To The Line Of Sight Of A Certificated Pilot in 

Command With A Safety Observer. PHILLIP COCHRAN will ensure any person 

acting as PIC meets the requirements set forth in this exemption request. 

Additionally, a safety observer will assist him at all times during flight time.

c. Flights Of DJI Phantom 4 UAS Will Be Conducted Pursuant To Specific 

Operating Limitations set forth in this exemption request.

In seeking this exemption, The PHILLIP COCHRAN proposes to commercially 

operate DJI Phantom 4 UAS for the special 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 UAS weighing less than 

55 pounds maximum gross weight: DJI Phantom 4 Unmanned Aircraft Systems. 

Proposed operations of any other 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 airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 400 feet above 

ground level (AGL), as indicated by the procedures specified in the operating 

documents unless a special request is made and approved by ATC. All altitudes 

reported to ATC must be in feet AGL.

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all 

times. This requires the PIC to be able to use human vision unaided by any 

device other than corrective lenses, as specified on the PIC’s FAA-issued airman 

medical certificate.

6. The use of first person view (FPV) by the PIC 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 PIC always maintains VLOS 

capability. The SO and PIC must be able to communicate verbally at all times. 

Electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation 

for the duration of the flight. The PIC 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 PIC with 

seeing and avoiding other air traffic and 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 request. 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 followed. 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 documents 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 which 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 PIC 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 properly 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 PIC 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 parts 

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 UAS 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 inspections.

17. The PIC 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 PIC meets the 

operator’s qualification criteria and demonstrates the ability to safely 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 

qualification 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 dedicated training sessions. During training, proficiency, and 

experience-building flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC 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 aeronautical 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 the 

Administrator upon request.

21. The UA may not be operated 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 

PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a 

pre- determined location within the planned operating area and land or be 

recovered in accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operating documents.

24. The PIC 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 Notice 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 potential 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. part 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 government 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 

any law enforcement official upon request.

29. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times.

30. The UAS may not be operated by 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 PIC, SO, operator trainees or 

essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently 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;

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 PIC 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 PIC, SO, operator trainees or essential persons do 

not present an undue hazard to those persons 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 Office (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 An Exemption From The Requirements Of Section 61.113(a) 

And (b) Would Not Adversely Affect Safety.

PHILLIP COCHRAN submits that the equivalent level of safety established by 

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to 

operate the DJI Phantom 4 UAS unless that PIC has demonstrated, by meeting 

minimum flight-hour and currency requirements, that the PIC is able to safely 

operate the DJI Phantom 4 UAS in a manner consistent with the exemption, 

including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. Considering PHILLIP 

COCHRAN’s proposed area of operations, and the operating limitations set forthabove; 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 DJI Phantom 4 UAS, The 

PHILLIP COCHRAN submits that the additional manned airmanship experience 
of a commercially certificated pilot would not correlate to the airmanship skills 

necessary for PHILLIP COCHRAN’s 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).

PHILLIP COCHRAN will not allow any PIC to operate the DJI Phantom 4 UAS 

unless that PIC has demonstrated, by meeting minimum flight-hour requirements 

or the DJI Phantom 4 UAS training and currency requirements, that the PIC is 

able to safely operate the DJI Phantom 4 UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. Specifically, 

the PIC 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 a 

minimum of 5 hours of those hours as 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 PIC must accomplish 3 takeoffs and landings in the 

preceding 90 days (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 PHILLIP COCHRAN’s 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 PIC 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 inclusive 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 PIC must accomplish 3 takeoffs 

and landings in the preceding 90 days (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 petitioner’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 experiencebuilding flights can also be conducted under the grant of exemption to 

accomplish the required flight time. During training, proficiency, and experience-
building flights the PIC is required to operate the UA with appropriate distances in 

accordance with 14 C.F.R 91.119.

Accordingly, The PHILLIP COCHRAN will ensure safe operations by not allowing 

any PIC to operate the DJI Phantom 4 UAS unless that PIC has demonstrated, 

by meeting minimum flight-hour and currency requirements, that the PIC is able 

to safely operate the DJI Phantom 4 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 An Exemption From The Requirements Of Section 91.7(a) 

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained 

because prior to every flight, PHILLIP COCHRAN will ensure that the DJI 

Phantom 4 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. 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 An Exemption From The Requirements Of Section 91.121 

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained 

because the altitude information of the DJI Phantom 4 UAS will be provided to 

the PIC 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 PHILLIP COCHRAN’s 

operation of the DJI Phantom 4 UAS within visual line of sight, at or below 500 

feet AGL, will ensure a level of safety equivalent to 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 UAS at ground level. The FAA has previously granted relief 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, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) 

Would Not Adversely Affect 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 DJI Phantom 4 UAS; (2) the limitations on the proposed flight operations; and 

(3) the location of the proposed flight operations. Accordingly, PHILLIP 

COCHRAN will ensure that he will safely operate the battery powered DJI 

Phantom 4 UAS during daylight hours in VFR conditions, with enough battery 

power to fly for a total duration of 23 minutes. Here, as in Exemption No. 11109, 

the technical specifications of the DJI Phantom 4 UAS; 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 DJI Phantom 4 UAS provide audible 

and visual warnings to the PIC 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 

critically low battery level, the DJI Phantom 4 UAS will descend and land 

automatically. Significantly, previous exemptions granted by the FAA concerning 

Section 91.151 establish that safety is not adversely 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 10650. 

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, 11064, 11065, 

11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not 

Adversely Affect Safety.

In seeking this exemption, PHILLIP COCHRAN submits 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 because PHILLIP COCHRAN will use trained 

technicians to perform maintenance, alterations, or preventive maintenance on 

the UAS using the methods, techniques, and practices prescribed in applicable 

operating documents such as the DJI Phantom 4 Instruction Manual. 

Furthermore, PHILLIP COCHRAN will document and maintain all maintenance 

records for the DJI Phantom 4 UAS. Since the DJI Phantom 4 UAS will be 

inspected as prescribed by the operating documents, PHILLIP COCHRAN will 

maintain the equivalent level of safety established by Sections 91.405(a), 

91.409(a)(1), and 91.409(a)(2). Likewise, the exemption sought will not adversely 

affect safety because PHILLIP COCHRAN will use trained technicians to perform 

maintenance, 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 DJI Phantom 4 UAS will be performed by trained technicians. 
Maintenance will be documented and maintained utilizing the monthly 

maintenance log. Significantly, previous exemptions granted by the FAA 

concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b) establish that safety is not adversely affected when the technical 

characteristics and operating limitations of the UAS are considered. In 

consideration of PHILLIP COCHRAN’s proposed operating limitations, the 

operating documents, and the technical aspects of the DJI Phantom 4 UAS, 

PHILLIP COCHRAN submits that safety will not be adversely affected by 

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 previously 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, 11156, 

11157, 11158, 11159, 11160, 11161).

7. The FAA May Prescribe Any 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, PHILLIP 

COCHRAN requests that the FAA prescribe special conditions for the intended 

operation of the DJI Phantom 4 UAS, 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 photography 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 security; and further, 

provides the authority for such 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 

special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI 

Phantom 4 UAS, 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 because 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 safety 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 Leading Edge’s 

intended operation of the DJI Phantom 4 UAS, 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 

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 Summary That Can Be Published In The Federal Register, stating: The Rules 

From Which PHILLIP COCHRAN Seeks Exemption:

PHILLIP COCHRAN 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 The Nature Of The Exemption PHILLIP COCHRAN Seeks:

This exemption will permit PHILLIP COCHRAN to commercially operate an 

Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and 

photography over certain areas of the United States.

Any Additional Information, Views, Or Arguments Available To Support The 

PHILLIP COCHRAN’s 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 determine 

if certain UAS may operate safely in the NAS. As such, PHILLIP COCHRAN’s 

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, PHILLIP COCHRAN will operate the DJI Phantom 

4 UAS safely in the NAS, without creating a hazard to users of the NAS, or the 

public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, PHILLIP COCHRAN 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 DJI Phantom 4 UAS 

commercially, without an airworthiness certificate, for the limited purpose of 

conducting aerial video and photography 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 

advancing the interests of the public, by allowing PHILLIP COCHRAN to safely, 

efficiently, and economically operate the DJI Phantom 4 UAS commercially within 

the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 
Modernization and Reform Act of 2012, Section 333, PHILLIP COCHRAN

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 Phillip Cochran to operate the DJI Phantom 4 UAS commercially for 

the purpose of conducting aerial video and photography over certain areas of the 

United States.

Dated: March 8, 2016

Respectfully submitted,

Phillip Cochran

790971 S. 3340 Rd.

Perkins, OK 74059

580-747-8161

phillipmcochran@gmail.com