FROM:

Donald A. Trowell Coeus 544 Flint Street Rock Hill, SC 29730 Tel: 843

- 637

- 9029 Email: datrowell@yahoo.com
TO:
DOCKET OPERATIONS ROOM W12

- 140 OF THE WEST BUILDING GROUND FLOOR 1200 NEW JERSEY AVENUE, SE. WASHINGTON, DC, 20590 Regulatory Docket No.

_____________

PETITION FOR EXEMPTION OF:

Coeus FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS PART 21, SUBPART H AND SECTIONS §§ 61.113(a) & (b), 91. 109, 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 COMMERCIALOPERATION OF DJI PHANTOM 2 VISION+ AND DJI PHANTOM 3 PROFESSIONAL UNMANNED AIRCRAFT SYSTEMSPURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)**SUMMARY**

Coeus (Donald A. Trowell) seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.109, 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 pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Coeu s to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of Real Estate Properties (for homeowners, realtors, home builders, home contractors and / or home inspectors for real estate marketing and inspection of home exteriors) as well as filming of special events, film s ets, scripted and unscripted television sets and landscape, conducting power line inspection, aerial mapping, surveying and search and
rescue over certain areas of the United States.**INTRODUCTION AND INTERESTS OF THE PETITIONER**

Coeus is a prod uction company based in South Carolina specializing in real estate videography, photography, music video production, special event production and film and televi sion production. Coeus’s objective is to conduct aerial photography and videography in order to provide high quality digital imaging and video content t o its clients, in particular to homeowners, real estate agents, realtors, home builders, home contractors, and/or home inspectors for real estate marketing and inspections of home exteriors as well a s filming of special events, film sets, scripted and unscripted television sets and landscape, conducting power line inspection, aerial mapping, surveying and search and rescue utilizing DJI Phantom 2 Vision+ and/or DJI Phantom 3 UAS. More specifically, Over Exposure aerial video and photography operations will serve in the following areas: • Aerial photography of houses / residential and commercial buildings and power lines • Aerial videography of houses / residential and commercial buildings and power l ines • Aerial event photography • Aerial event filming • Aerial Film & Television production • Aerial search and rescue and safety inspections • Increase public knowledge of UAS and promote safe UAS operations.

**Unmanned Aircraft Systems: DJI Phantom 2 Vision+, Phantom 3 Professional UAS** 

Coeus seeks an exemption to operate DJI systems DRONES for compensation or hire within the NAS. The DJI Phantom 2 Vision+, DJI Phantom 3 Professional are vertical takeoff and landing (VTOL) Unmanned Aircrafts (UAS) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 2+, DJI Phantom 3 Professional have a maximumgross weight of approximately 2 pounds 11 ounces, while having a length of 16 inches width of

16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJI Phantom 2 Vision+, DJI Phantom 3 Professional UAS are equipped with four main rotors; driven by Lithium Polymer battery powered electric motors. The DJI Phantom 2 Vision+, DJI Phantom 3 Professional UAS that will be operated by Coeus (trained professional), 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, Coeus, 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 peti tions the Administrator to commercially operate the DJI Phantom 2 Vision+, DJI Phantom 3 Professional UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.109, 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, Coeus operation of DJI Phantom 2 Vision+, DJI Phantom 3 Professional 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, Subpa rt H. Accordingly, Coeus 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 airworth iness certificate. Coeus submits that the requested relief is proper since an equivalent level of safety will be ensured. Coe us will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS’s using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly MaintenanceLog, and DJI Phantom 2 Vision+, DJI Phantom 3 Professional Instruction Ma nual). Furthermore,

Co e us will document and maintain all maintenance records for the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UAS.
Relief from certain requirements of Section 61.113(a) and ( b), entitled Private pilot privileges and limitations : Pilot In Comman d, is requested by Coeus to the extent necessary to allow a Pilot in Command (PIC) holding a Commercial Pilots License, and who has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision+, DJI Phantom 3 Professional UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, ves sels, vehicles and structures.

Coeus seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Phantom 2 Vision+, DJI Phantom 3 Professional UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, S ubpart H. As such, Coeus submits that it will ensure that the Phantom 2 Vision+, DJI Phantom 3 Professional UAS are in an airworthy condition, prior to every flight, by determining that the UAS’s are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+, DJI Phantom 3 Professional Instruction Manual), and that the aircraft are in a conditio n for safe flight. Coeus also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJI Phantom 2 Vision+, DJI Phantom 3 Professional UAS will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 2 Vision+, DJI Phantom 3 Professional UA will be provided to the PIC via Global Positionin g 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 infor mation, combined with Coeus’s operation of the DJI Phantom 2 Vision+, DJI Phantom 3 P rofessional UAS within visual line of sight, at or below 200 feet AGL, will ensure a level of safety equivalent to Section 91.121.Additionally, Coeus seeks an exemption from the requirements of Section 91.151(b), entitled

Fuel requirements for flight in VFR conditions. Coeus submits that safety will not be affected by operation of the DJI Phantom 2 Vision+, DJI Phantom 3 Professional UA 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 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, Coeus provides the following inform ation 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: Donald A. Trowell Coeus 544 Flint Street Rock Hill, SC 68048 Tel: 843

- 637

- 9029 Email: datrowell@yahoo.com B. The Specific Sections Of 14 C.F.R. From Which Coeus Seeks Exemption. 1. (removed) 2. Coeus 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. Coeus Seeks Exemption From The Requirements Of Section 91.121. Section 91.121, entitled Altimeter settings, subse ction (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. Coeus 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. Coeus 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. Coeus Seeks Exemption From The Requirements Of S ection 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 mainte nance, rebuilding, or alteration unless

-- (1) It has been approved for return to service by a pers on authorized under § 43.7 of this chapter[.]7. Coeus Seeks Exemption from The Requirements Of Sections 91.409( a)(1) And

91.409(a)(2). Section 91.409, e ntitled 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 wi th 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. Coeus Seeks Exem ption 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, a nd 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 ea ch airframe, engine, propeller, rotor, and applianc e. (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 i nspection 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 revi sion 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 engin es, 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 owne r 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. Th e Extent Of Relief Coeus Seeks And The Reason Coeus Seeks The Relief.

1 . Extent Of Relief Coeus Seeks And The Reason UAV Aerial Video 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 Su pplemental Pilot Certificate, as well as a current and validairman 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, Coeus submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 2 Vision+, Phantom 3 Professional UA unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 2 Vision+, Phantom 3 Professional UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate d istances from people, vessels, vehicles and st ructures. Further, Coeus submits that all flights of the DJI Phantom 2 Vision+, Phantom 3 Professional UAS, conducted by the PIC pursuant to the grant of this Petition: (1) wil l be incidental to Coeus business; and (2) will not carry passengers or property for compensation or hire.

Coeus believes that though UAS are not traditional aircrafts, a PIC operating the UA must have knowledge of Airman rules, basic Airspace and comply with all the rules proposed by th e FAA. However, considering the fact that a UA is almost like a toy, weighing less than a skinny person, the PIC may be except from obtaining a Private Pilot Certificate, a Sports Certificate, a Recreational Certificate considering these certificates requi re flight hours of several thousand tons weighing aircrafts. The o peration of UAS by Coeus is strictly for entertainment / informational purposes, thus the operators of the UAS have a career and / or freelance employment as a Camera Operator and Cinematographer and will benot be entertaining a career as a pi lot. Lastly, Coeus PICs will operate the UAS no higher than 400 feet, consequently causing no danger t o any other aircraft in the NAS. However, Coeus Proposes PIC Certification as a Supplemental pilot a nd a minimum requirement of successfully completed private pilot ground school. Additionally, supplemental pilots without a current FAA private pilot certificate must have successfully passed the private pilot, commercial pilot, or airline transport pilot knowledge test within the past 24 calendar months. 2 . Extent Of Relief Coeus Seeks And The Reason UAV Aerial Video Seeks Relief From Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required t o allow Coeus to determine that the DJI Phantom 2 Vision+, Phantom 3 Professional UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating do cuments (i.e., the Coeus Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+, Phantom 3 Professional In struction Manual). Coeus seeks the requested relief because the DJI Phantom 2 Vision+, Phantom 3 Professional UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Sub part H. Therefore, Coeus will ensure that the DJI Phantom 2 Vision+ UAS are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+, Phantom 3 Professional Instruction Manual) 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 Coeus Seeks And The Reason UAV Aerial Video 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 2 Vision+, Phantom 3 Professional UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from theUA 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 g round level (AGL), Coeus seeks the requested relief because the DJI Phantom 2 Vision+, Phantom 3 Professional UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field requested relief because the DJI Phantom 2 Vision+, Phantom 3 Professional 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 so ught 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 2 Vision+, Phantom 3 Professional UAS are equipped wi th 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 . E xtent Of Relief Coeus Seeks And The Reason UAV Aerial Video 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 po wered DJI Phantom 2 Vision+, Phantom 3 Professional UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruis ing speed, to fly after that for at least 4.5 minutes. Coeus seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 2 Vision+, Phantom 3 UA will severely constrain the pra cticality of any aerial videoor still photo flight operations that Coeus proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJI Phantom 2 Vision+, Phantom 3 Professional UAS operat ing do cuments, and Coeus proposed operating limitatio ns, ensure that Coeus will safely operate the battery powered DJI Phantom 2 Vision+, Phantom 3 Professional 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 13.5 minut es to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

5 . Extent Of Relief Coeus Se eks And The Reason Coeus Seeks Relief From Section 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 airworth iness certificate, Coues requests relief from these Sections because the DJI Phantom 2 Vision +, Phanto m 3 Professional UAS do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 2 Vision+, Phantom 3 Professional UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certifi cate. Accordingly, Coeus 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 do cuments (i.e., the Coeus Aerial Operations Manual, Monthly Maintenanc e Log, and DJI Phantom 2 Vision+, Phantom 3 Professional Instruction Man ual). Furthermore, Coeus will document and maintain all maintenance records for the DJI Phantom 2 Vision+, Phantom 3 UAS. D. The Reasons Why Granting Coeus 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 Over Exposure to safely, efficiently, and economically perform aerial video and photography of real estate, spec ial events, film sets, and landscape over certain areas of the United States. Additionally, use of the DJI Phantom 2 Vision+, Phantom 3 Professional UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy . Notabl y, the benefits of Coeus’s proposed operation of the DJI Phantom 2 Vision+, Phantom 3 UAS will be realized without implicating any privacy issues. 1. The Public Will Benefit From Decreased Congestion Of The NAS. The DJI Phantom 2 Vision+, Phantom 3 Professional UA 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 exe mption allowing the use of a DJI Phantom 2 Vision+, Phantom 3 Professional 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. Further more, 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 2 Vision+, Phantom 3 Professional UA do not require an airport to takeoff or land. L ikewise, 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 2 Vision+, Phantom 3 UAS. Conducting aerial acquisitions with the DJI Phantom 2 Vision+, Phantom 3 Professional UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated duringtraditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Phantom 2 Vision+, Phantom 3 Professional 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 2 Vision+, Phantom 3 Professional UA, 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 2 Vision+, Phantom 3 Professional 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 op erations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 2 Vision+, Phantom 3 UAS (weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, 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 a nd Photography Operations With The DJI Phantom 2 Vision+, Phantom 3 UAS Will Benefit The Economy. In addition to being safe and efficient, the DJI Phantom 2 Vision+, Phantom 3 Professional is also an economical alternative to using manned aircraft to
con duct similar aerial operations. As such, operation of the DJI Phantom 2 Vision+, Phantom 3 Professional UAS will allow United States based companies, like Over Exposure, to remain competitive and contribute to growth of the U.S.economy. Specifically, wit h 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 2 Vision+, Phantom 3 Professional 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 t raditional manned aircraft. By operating the DJI Phantom 2 Vision+, Phantom 3 Professional UAS, companies such as Coeus, 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 2 Vision +, Phantom 3 Professional UAS, provides a stable workforce that increases consumer spending; improves local, sta te, 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, Coeus proposed operation of the DJI Phantom 2 Vision+, Phantom 3 UAS will not implicate any privacy issues. Specifically, the DJI Phantom 2 Vision+, Phantom 3 Professional UAS will be operated only in compliance with operat ing documents (i.e., the Coeus Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+, Phantom 3 Professional Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordan ce 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 T he Rule From Which Coeus Seeks Exemption.1. Reasons Why The DJI Phantom 2 Vision+, Phantom 3 Professional UAS Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333. In consideration of the size, wei ght, speed, and limited operating area associated with the unmanned aircraft and its operation, Coeus operation of the DJI Phantom 2 Vision+, Phantom 3 Professional UAS meet the conditions of FMRA Section 333, and will not require an airworthiness certifi cate 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, th e Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rule

- making 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, op erational 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.

-- I f the Secretary determines under thissection 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 seeki ng this exemption, Coeus submits that the DJI Phantom 2 Vision+, Phantom 3 Professional UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 2 Vision+, Phantom 3 Professional UAS; (b) the pilot certification requirement; and (c) the specific operating limitations. **a. The Specifications Of The DJI Phantom 2 Vision+, Phantom 3 Professional UAS Demonstrate Its Safe Characteristics.**  **The DJI Phantom 2 Vision+, Phantom 3 Professional 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.**  i. Technical Specifications Of The DJI Phantom 2 Vision+, Phantom 3 Professional UAS. The technical specifications of the DJI Phantom 2 Vision+, Phantom 3 Professional UAS is set forth by the DJI Phantom 2 Vision+, Phantom 3 Professional Specifications and Data Sheet, attached hereto as Exhibit A. ii. The DJI Phantom 2 Vision+, Phantom 3 Professional UAS Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area. The DJI Phantom 2 Vision+, Phantom 3 Professional UAS may be operated in both ma nual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Phantom 2 Vision+, Phantom 3 UAS is provided at pages 25

- 35 of the DJI Phantom 2 Vision+, User Manual, attached hereto as Exhibit B & D (Phantom 3 User Manual will be available after May 15, 2015; however, is very similar to DJI Phantom 2 Vision+ User Manual). iii. The DJI Phantom 2 Vision+, Phantom 3 Professional 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 2 Vision+ UAwill remains stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 Vision+, Phantom 3 Professional UA does not reacquire control link data from the GCS, the UA will assume that the Control Link is lost and the UA 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 2 Vision+, Phantom 3 Professional UAS are set forth at pages 27 through 29 of the DJI Phantom 2 Vision+, (Phantom 3) Professional User Manual, attached hereto as B & D. iv. The DJI Phantom 2 Vision+, Phantom 3 Professional GCS And Its Operation. A complete description of the operation and specifications of the DJI Phantom 2 Vision+, Phantom 3 GCS and flight control software is provided at pages 32 through 43 of the DJI Phantom 2 Vision+, (Phantom 3) Professional User Manual. DJI Phantom 2 Vision+ User Manual is attached hereto as Exhibit B & D. **b. Flight Operations Of DJI Phantom 2 Vision+, Phantom 3 Profess ional UAS Are**  **Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.**  Coeus will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the DJI Phan tom 2 Vision+, Phantom 3 Professional UAS. Additionally, a safety observer will assist all pilots during flight time. **c. Flights Of DJI Phantom 2 Vision+, Phantom 3 Professional UAS Will Be Conducted Pursuant To Specific Operating Limitations.**  In seekin g this exemption, proposes to commercially operate DJI Phantom 2 Vision+, Phantom 3 Professional UAS for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limit ations:
1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASsweighing less than 55 pounds maximum gross weight: DJI Phantom 2 Vision+, Phantom 3 Professional Un manned Aircraft System. 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 photograph y for homeowners, Realtors, home builders, contractors, home inspectors for use in real estate marketing and real estate inspections. Additionally, aerial video and photography may be conducted on occasional basis for film and television sets, special even ts and landscape photography, conducting power line inspection, aerial mapping, surveying as deemed necessary. 3. The UAS may not be flown at an indicated airspeed exceeding 29 knots (15 m/s). 4. The UAS must be operated at an altitude of no more than 200 (500 per the User Manual) 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 P IC 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 d esignation for theduration 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 follo wed. 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 maint enance 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 ent ry 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 docume nts. 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 i nspections. 17. The PIC must possess at least a Sup p lemental Pilot certificate and at least a current third

- class medical certificate. Supplemental pilots must have, at a minimum, successfully completed private pilot ground school. Additionally, suppleme ntal pilots without a current FAA private pilot certificate must have successfully passed the private pilot, commercial pilot, or airline transport pilot knowledge test within the past 24 calendar months. 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 maintainingappropriate 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 mu st 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 cond itions (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. Th e 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 predetermined 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 crui singspeed 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 gran t 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. 2 8. 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 UAS 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 operatormust 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 o perating 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 Adve**  **rsely Affect Safety.** Coeus 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 2 Vision +, Phantom 3 Professional UAS unless that PIC has demonst rated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision +, Phantom 3 Professional UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintai ning appropriate distances from people, vessels, vehicles and structures.Considering Coeus proposed area of operations, and the operating limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to those of co mmercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 2 Vision+, Phantom 3 Professional UAS, Coeus submits that the additional manned airmanship experience of a commercially certificate d pilot would not correlate to the airmanship sk ills necessary for Coeus 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 thos e presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 111 53, 11156, 11158, 11159, 11160, 11161). **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 prio r to every flight, Coeus will ensure that the DJI Phantom 2 Vision+, Phant om 3 Professional 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 Wh y 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 2 Vision+, Phantom 3 Profession al UA will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCSfor active monitoring of the flight path and altitude. This altitude informat ion, combined with Coeus’s operation of the DJI Phantom 2 Vision+, Phantom 3 Professional 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 UASs 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 Exempti on 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 Pha ntom 2 Vision+, Phantom 3 Professional UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operat ions. Accordingly, Coeus will ensure that it will safely operate the battery powered DJI Phantom 2 Vision+, Phantom 3 Professional UA during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes

. Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 2 Vision+, Phantom 3 Professional UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of sa fety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 2 Vision+, Phantom 3 Professional UAS provide audible and visual warnings to the PIC at the GCS whenthe 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 Vision+, Phantom 3 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 here in (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 seeki ng this exemption, Coeus submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements establishe d by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Coeus will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., the Coeus Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+, Phantom 3 Professional Instruction Man ual). Furthermore, Coeus will document and maintain all maintenance records for the DJI Phantom 2 Vision+, Phantom 3 Professional UAS. Since the DJI Phantom 2 Vision+, Phantom 3 Professional UAS will be inspected as prescribed by the op erating documents, Coeus will maintain the equivalentlevel of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 2 Vision+ User Manual is attached hereto as Exhibit B & D; a copy of the DJI Phantom 2 Vision+, Phantom 3 UAS Maintenance LOG is attached hereto as Exhibit C. Likewise, the exemption sought will not adversely affect safety because Coeus will use trained technicians to perform maintenance, alterations or preventive maintenanc e on the UAS using the methods, techniques, and practices prescribed by the operating documents. Furthermore, the exemption sou ght 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 2 Vision+, Phantom 3 Professional UAS will be performed by trained technicians. Maintenance will be documen ted 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 advers ely affected when the technical characteristics and operating limitations of the UAS are considered. I n consideration of Coeus proposed operating limitations, the operating documents, and the technical aspects of the DJI Phantom 2 Vision +, Phantom 3 Professional UAS, Coeus s ubmits 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 Fo r 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 S pecial Conditions, Coeus requests that the FAA prescribe special conditions for the intended operation of the DJI Phant om 2 Vision+, Phantom 3 Professional UAS, which contain such safetystandards 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), 9 1.121, 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 opera tion of the DJI Phantom 2 Vision+, Phantom 3 Professional 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, ent itled 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 des ign 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 prescr ibe spec ial conditions for Coeus’s intended operation of the DJI Phantom 2 Vision+, Phantom 3 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to thatestablished 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). **F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Coeus**  **Seeks Exe mption:**  Coeus 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 Coeus Seeks: This exemption will permit Coeus to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States. **G. Any Additional Information, Views, Or Arguments Available To Suppo rt UAV**  **Aerial Video 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, Coeus 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 t o operate without airworthiness certification. As discussed in detail above, Coeus will operate the DJI Phantom 2 Vision +, Phantom 3 Professional UAS safe ly 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, Coeus seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization a nd Reform Act of 2012 (FMRA), which will permit safe operation of theDJI Phantom 2 Vision+, Phantom 3 Professional UAS commercially, without an airworthiness

certificate, for the limited purpose of conducting aerial video and photography over certain
area s 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 UAV Aerial Video to safely, efficiently, and economically operate the DJI Phantom 2 Vision+, Phantom 3 Professional UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Coeus 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 Coeus to operate the DJI Phantom 2 Vision +, Phantom 3 Professional UAS commercially for the purpose of conducting aerial video and photography of Real Estate Properties (for homeowners, realtors, home builders, home contractors and / or home inspectors for real estate marketing and inspection of home exteriors) as well as filming of special events, film sets, scripted and unscripted television sets and landscape as well as conducting power line inspection, aerial mapping, surveying and search and rescue over certain areas of the United States.
Respectfully submitted by, Donald A. Trowell

Donald A. Trowell Coeus 544 Flint Street Rock Hill, SC 29730 843

- 637

- 9029 datrowell@yahoo .comAppendixes:

A

– DJI Phantom 2 Vision+ Specifications Data Sheet B

– DJI Phantom 2 Vision+ Manufacturer’s User Manual C

– DJI Phantom 3 Professional Specifications Data Sheet D

– DJI Phantom 3 Manufacturer’s User Manual E

– Monthly Maintenance LogAPPENDIX

– A DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS Coeus only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real

-time altitude and location informa tion to the PIC via the linked monitor (smart phone/tablet devices)

.

1.1 DJI Phantom 2 Vision+ 1.1.1 Aircraft 1.1.1.1 Supported Battery

– DJI 5200mAH LiPo Battery 1.1.1.2 Weight (Battery & Propellers Included)

– 2lbs 11.810oz (1242g) 1.1.1.3 Hover Accuracy (Ready to Fly)

– Vertical: .8m; Horizontal: 2.5m 1.1.1.4 Max Yaw Angular Velocity

- 200 0/s 1.1.1.5 Max Tilt Angel

- 35 0 1.1.1.6 Max Ascent Speed

– 6m/s 1.1.1.7 Max Descent Speed

– 2m/s 1.1.1.8 Max Flight Speed

– 15m/s (NOT RECOMMENDED) 1.1.2 Gimbal 1.1.2.1 Working Current

– Static: 750mA; Dynamic: 900mA 1.1.2.2 Control Accuracy

- ±0.03 0 1.1.2.3 Controllable Range

– Pitch:

-90 0

- 0 0 1.1.2.4 Maximum Angular Speed

– Pitch: 90 0/s 1.1.3 Camera 1.1.3.1 Operating Temperature Range

- 32 0F

- 1040F (00C

- 40 0C) 1.1.3.2 Sensor Size

– 1/2.3” 1.1.3.3 Effective Pixels

– 14M 1.1.3.4 Resolution

– 4384x3288 4.1.3.5 HD Video Recording

– 1080p30 & 720p 4.1.3.6 Recording Field of View

- 110 0/850 1.1.4 Transmitter 1.1.4.1 Operating Frequency

– 5.72 8GHz

– 5.85GHz 1.1.4.2 Communication Distance (unobstructed)

– FCC Compliance: 800m 1.1.4.3 Receiver Sensitivity (1%PER)

- - 93dBm 1.1.4.4 Transmitter Power

– FCC Compliance: 100mW1.1.4.5 Working Voltage

– 120mA@3.7V

1.1.5 Range Extender 1.1.5.1 Operating Frequency

– 2412

- 2462MHz 1.1.5.2 Communication Distance (unobstructed)

– 500

- 700m 1.1.5.3 Transmitter Power

– 20dBm 1.1.5.4 Power Consumption

– 2WAPPENDIX

- B DJI Phantom 2 Vision+ Manufacturer's User Manual (uploaded in a separate attachment, a 72

- page document)APPENDIX

– C DJI PHANTOM 3 TECHNICAL SPECIFICATIONS **AIRCRAFT Weight (Including Battery And Propellers)**  1280 g **Diagonal Size (Including Propellers)** 590 mm **Max Ascent Speed** 5 m/s **Max Descent Speed** 3 m/s **Hover Accuracy** • Vertical: +/

- 10cm • Horizontal: +/

- 1m **Max Speed** 16 m/s (ATTI mode, no wind) **Max Altitude Above Sea Level** 6000 m **Operating Temperature** 0°C to 40°C **Gps Mode** GPS/GLONASS **GIMBAL Controllable Range**  Pitch

- 90° to +30° **Stabilization** 3

- axis (pitch, roll, yaw) **REMOTE CONTROLLER Operating Frequency**  2.400 GHz

- 2.483 GHz **Max Distance** 2000m (outdoors/ unobstructed **) Video Output Port**  USB **Operating Temperature**  0°C

- 40°C **Battery** 6000 mAh LiPo 2S **Mobile Device Holder** For tablet or phone Receiver **Sensitivity (1%Per)**

- 101 dBm ±2 dBm **Transmitter Power (Eirp)** • FCC: 20 dBm • CE: 16 dBm **Working Voltage** 1.2 A @7.4 V**BATTERY CHARGER Voltage**  17.4 V Rated Power **Phantom 3 Professional** 100 W

**INTELLIGENT FLIGHT BATTERY Capacity**  4480 mAh **Voltage** 15.2 V **Battery Type** LiPo 4S **Energy** 68 Wh **Net Weight** 365 g **Max Flight Time** Approximately 23 minutes **Operating Temperature**

- 10°C to 40°C **Max Charging Power** 100 WAPPENDIX

– D DJI Phantom 3 Professional Manufacturer’s User Manual (uploaded in a separate attachment, a 58

- page document)APPENDIX

– E MONTHLY MAINTENANCE LOG

UAS # Date Issue

Discovered Date Issue

Addressed Issue Description

& Maintenance Conducted Maintenance

Performed By: Print & Sign Software Updates Airframe Engines Propellers Camera Gimbal Landing Gear Vibration Dampening Other: