### 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 HAND 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 2VISION+ AND DJI PHANTOM 3 PROFESSIONAL UNMANNED AIRCRAFT SYSTEMSPURSUANTTO 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 ofthe FAA

Modernization and Reform Act of 2012 (FMRA). This exemption will permit Coeus 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 

## I or home inspectors for real estate marketing and inspection of home exteriors) as well as filming ofspecial events, film sets, scripted and unscripted television sets

and landscape, conducting power line inspection, aerial mapping, surveying and search and

rescue over certain areas ofthe United States.INTRODUCTION AND INTERESTS OF THE PETITIONER

Coeus is a production company based in South Carolina specializing in real estate videography, photography, music video production, special event production and film and television production. Coeus's objective is to conduct aerial photography and videography in ordertoprovide high quality digital imaging and video content to its clients, in particularto homeowners, real estate agents, realtors, home builders, home contractors, and/or home inspectors for real estate marketing and inspections of home exteriors as well as 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 thefollowing areas:

• Aerial photography of houses 

## I residential and commercial buildings arid power lines

• Aerial videography of houses 

## I residential and commercial buildings and power lines

• Aerial event photography

• Aerial eventfilming

• 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 2Vision+, DJI Phantom 3 Professional are vertical takeoffand 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 ofapproximately 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 2Vision+, 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 thatwill be operated by Coeus (trained professionalL will be registered in accordance with 49 U.S.C. 44103, Registration ofAircraft, 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 tothe provisions ofthe FederalAviation Regulations (14 C.F.R. 

### § 11.61) and the FAA Modernization andReform Actof2012 (FMRA), Section 333, Special Rules for Certain UnmannedAircraftSystems, hereby petitions the Administratorto commercially operate the DJI Phantom 2 Vision+, DJI Phantom 3 Professional UAS in the National Airspace System (NASL and for an exemption from the requirements of 14 C.F.R 

### §§ 61.113(a) 

### & (bL 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 ofthe 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, Subpart 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 applyto aircraft with an airworthiness certificate. Coeus submits that the requested relief is propersince an equivalent level ofsafety will be ensured. Coeus will use experienced personnel ortechnicians to perform maintenance, alterations, or preventive maintenance on the UAS's usingthe methods, techniques, and practices prescribed in the operating documents (i.e., Monthly MaintenanceLog, and DJI Phantom 2 Vision+, DJI Phantom 3 Professional Instruction Manual). Furthermore, Coeus will document and maintain all maintenance records forthe OJI Phantom 2 Vision+ and DJI Phantom 3 Professional UAS.

Relieffrom certain requirements ofSection 61.113(a) and (b), entitled 

### Privatepilotprivileges andlimitations: Pilot In Command, 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, vessels, vehicles and structures.

Coeus seeks relieffrom Section 91.7(a), entitled 

### Civilaircraftairworthiness, 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, Subpart H. As such, Coeus submits that it will ensure that the Phantom 2Vision+, DJI Phantom 3 Professional UAS are in an airworthy condition, priorto every flight, by determiningthat 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 thatthe aircraft are in a condition for safe flight. Coeus also seeks an exemption from the requirements ofSection 91.121, entitled

### AltimeterSettings, as the DJI Phantom 2Vision+, DJI Phantom 3 Professional UAS will not have atypical barometric altimeter

onboard. However, altitude information ofthe OJI Phantom 2 Vision+, DJI Phantom 3 Professional UA 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 ofthe flight path. This altitude information, combined with Coeus's operation ofthe DJI Phantom 2Vision+, DJI Phantom 3 Professional UAS within visual line ofsight, at or below 200 feet AGL, will ensure a level ofsafety equivalent to Section 91.121.Additionally, Coeus seeks an exemption from the requirements ofSection 91.151(b), entitled Fuel requirements forflight in VFR conditions. Coeus submits that safety will not be affected by operation ofthe DJI Phantom 2Vision+, DJI Phantom 3 Professional UA during daylight hours in visual meteorological conditions (VMC) undervisual flight rules (VFR), with enough battery power to fly for atotal duration ofapproximately 13.5 minutes to thefirst point of intended landing and, assuming normal cruising speed, tofly afterthat for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, Coeus provides the following information in support of its petition for exemption: 

### A. Name AndAddress OfThe Petitioner. The name and address ofthe Petitionerand point ofcontact is: Donald A. Trowell Coeus 544 Flint Street Rock Hill, SC 68048 Tel: 843-637-9029 Email: datrowell@yahoo.com B. The Specific Sections Of14 C.F.R. From Which Coeus Seeks Exemption. 

### 1. (removed) 2. Coeus Seeks Exemption From The Requirements OfSection 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 OfSection 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 orflight level ofthat aircraft, as

. the case may be, by reference to an altimeterthat is set, when operating-- 

### (!) Below 18,000feet MSL, to--

### (i) The current reported altimeter setting ofastation along the route and within 100 nautical miles ofthe aircraft; (ii) Ifthere is no station within the area prescribed in paragraph (a}(1}(i) ofthis section, the current reported altimeter setting ofan appropriate available station; or (iii) In the case ofan aircraft not equipped with a radio, the elevation ofthe departure airport oran appropriate**altimete~** 

### setting available before departure.

4. Coeus Seeks Exemption· From The Requirements Of Section 91.151(b). Section 91.151, entitled Fuel requirements forflight in VFR conditions, subsection (b), states the following: (b) No person may begin aflight in a rotorcraft underVFR conditionsunless (considering wind and forecast weather conditions) there is enough fuel to flyto the first point of intended landing and, assuming normal cruising speed, to fly afterthatfor 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 thefollowing: Each owneroroperatorofan aircraft- (a) Shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter[.]

6. Coeus Seeks Exemption From The Requirements Of Section 91.407(a}(1} Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, oralteration, 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 ofthis chapter[.]7. Coeus 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) ofthis section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part43 ofthis chapter and has been approved for return to service by a person authorized by§ 43.7

- ofthis chapter; or (2) An inspection forthe issuance ofan airworthiness certificate in accordance with part 21 ofthis chapter. 8. Coeus 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 forthe periods specified in paragraph (b) ofthis section: (1) Records ofthe 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 ofan aircraft. The records must include-- (i) A description (or reference to data acceptable to the Administrator) ofthe work performed; and (ii) The date ofcompletion ofthe work performed; and (iii) The signature, and certificate number ofthe person approving the aircraftfor

- return to service. (2) Records containingthe following information: (i) The total time in service ofthe 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 ofall items installed on the aircraft which are required to be overhauled on aspecified time basis. (iv)The current inspection status ofthe aircraft, including thetime since the last inspection required bythe inspection program underwhich the aircraft and its appliances are maintained. (v) The current status ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD orsafety directive numberand revision date. IftheAD orsafety directive involves recurring action, thetime and date when the next action is required. (vi) Copies ·oftheforms prescribed by§43.9(d) ofthis chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b} The owneroroperator shall retain the following records forthe periods prescribed: (1) The records specified in paragraph (a)(1) ofthis section shall be retained until the work is repeated orsuperseded by otherworkorfor 1year afterthe work is performed. (2) The records specified in paragraph (a)(2} ofthis section shall be retained and transferred with the aircraft atthe timethe aircraft is sold. (3} A list ofdefects furnished to a registered owner oroperator under§ 43.11 of this chapter shall be retained untilthe defects are repaired and the aircraft is approved for return to service. 

### C. The Extent Of ReliefCoeus SeeksAndThe Reason CoeusSeeks 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 tothe extent necessary to allow a PIC holding a Supplemental Pilot Certificate, as well as acurrent and validairman medical certificate, and who has met certain flight-hour and currency requirements, to conduct the proposed UAS flight operationsfor 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 ofan aircraft in connection with any business or employment if: (1) The flight is only incidental tothat business or employment; and (2) The aircraft does not carry passengers or propertyfor compensation or hire. As set forth more fully below, Coeus submits that an equivalent level ofsafety 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, demonstratingthatthe PIC is able to safely operate eitherthe DJI Phantom 2Vision+, 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 distances from people, vessels, vehicles and structures. Further, Coeus submits that all flights ofthe DJI Phantom 2 Vision+, Phantom 3 Professional UAS, · conducted bythe PIC pursuant tothe grant ofthis Petition: (1) will be incidental to Coeus business; and (2) will not carry passengers or property for compensation or hire.

Coeus believes thatthough UAS are not**tradi~ional** aircrafts, a PIC operating the UA must have knowledge ofAirman rules, basic Airspace and comply with all the rules proposed by the

## FAA. However, considering the fact that a UA is almost like

atoy, weighing less than askinny person, the PIC may be except from obtaining

a Private Pilot Certificate, a Sports Certificate, a Recreational Certificate considering these certificates require flight hours ofseveral thousand tons weighing aircrafts. The operation of UAS by Coeus is strictlyfor entertainment

## I informational purposes, thus the operators ofthe UAS have a career and 

## I or**freelan~e** employment as a Camera Operator and Cinematographer and will benot be entertaining a career as a pilot. Lastly, Coeus PICs will operate the UAS no higherthan 400 feet, consequently causing no dangerto any other aircraft in the NAS. However, Coeus Proposes PIC Certification as-a Supplemental pilot and a minimum requirement ofsuccessfully 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 to allow Coeus to determinethatthe DJI Phantom 2 Vision+, Phantom 3 Professional UAS are in airworthy condition priorto everyflight by ensuring that the UAS is incompliance with the operating documents (i.e., the Coeus Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+, Phantom 3 Professional Instruction Manual). Coeus seeks the requested relief because the DJI Phantom 2Vision+, Phantom 3 Professional UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Coeus will ensure thatthe 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 2Vision+, Phantom 3 Professional Instruction Manual) priorto every flight, and further, determine thatthe aircraft are in condition forsafe 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 ofthe DJI Phantom 2Vision+, 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 tothe PIC atthe ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to airtraffic control (ATC) in feet above ground level (AGLL Coeus seeks the requested relief because the DJI Phantom 2Vision+, Phantom 3 Professional UA's altimeter may be set on the ground to zero feet AGL, ratherthan the local barometric pressure

orfield 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 orfield altitude, before each flight. Considering the limited altitude ofthe proposed operations, relieffrom 14 CFR 91.121 is soughtto the extent necessary to comply with the applicable conditions and limitations stated below. As morefully set forth herein, an equivalent level ofsafetywill be maintained since the DJI Phantom 2Vision+, Phantom 3 Professional UAS are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that aground level pressure setting will be established priorto each flight, and provides the PIC with altitude information ofthe UA on the heads-up display ofthe GCS.

4. Extent Of Relief Coeus Seeks And The Reason UAV Aerial Video Seeks Relief From Section 91.151(b). Relieffrom Section 91.151(b) entitled Fuel requirements forflight in VFR conditions, is requested to the extent required to allowflights ofthe battery powered DJI Phantom 2Vision+, Phantom 3 Professional UAS during daylight hours in visual meteorological conditions (VMCL undervisual flight rules (VFRL for atotal duration of 13.5 minutesto the first point ofintended landing and, assuming normal cruising speed, tofly afterthatfor at least 4.5 minutes. Coeus seeks the requested relief because without an exemption from Section 91.151(b), theflight time duration ofthe battery powered DJI Phantom 2 Vision+, Phantom 3 UA will severely constrain the practicality of any aerial videoorstill photoflight operations that Coeus proposes to conduct pursuantto this Petition. Significantly, as set forth below,thetechnical specifications ofthe OJI Phantom 2 Vision+, Phantom 3 Professional UAS operating documents, and Coeus proposed operating limitations, ensure that Coeus will safely operatethe battery powered OJI Phantom 2Vision+, Phantom 3 Professional UAS during daylight hours in visual meteorological conditions (VMC), undervisual flight rules (VFR), with enough battery powertoflyforatotal duration of 13.5 minutestothe first point of intended landing and, assuming normal cruising speed, tofly afterthatfor at least 4.5 minutes

..

5. Extent Of Relief Coeus Seeks And The Reason Coeus Seeks Relief From Section

. 91.405(a), 91.407(a)(1L 91.409(a)(l) 

### &(a)(2), And 91.417{a) 

### &(b). Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(1) 

### & (a)(2), and 91.417(a) 

### & (b) only applyto aircraft with an airworthiness certificate, Coues requests relief from these Sections because the DJI Phantom 2 Vision+, Phantom 3 Professional UAS do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 2 Vision+, Phantom 3 Professional UAS meetthe conditions of FMRA Section 333 foroperation without an airworthiness certificate. Accordingly, Coeus will use trained technicians to perform**maint~nance,** alterations, or preventive maintenance on the UAS usingthe methods, techniques, and practices prescribed in the UAS operating documents .(i.e., the Coeus Aerial Operations Manual, Monthly Maintenance Log, and OJI Phantom 2Vision+, Phantom.3 Professional Instruction Manual). Furthermore, Coeus will document and maintain all maintenance records forthe OJI Phantom 2 Vision+, Phantom 3 UAS. D. The Reasons Why Granting Coeus Request WouldBe In The Public Interest; That Is, How It Would Benefit The PublicAsA Whole.Grantingthe present Petition will furtherthe public interest by allowing Over Exposure to safely, efficiently, and economically perform aerial video and photographyof real estate, special events, film sets, and landscape over certain

areas ofthe United States. Additionally, use ofthe DJI Phantom 2 Vision+, Phantom 3 Professional UAS will decrease congestion ofthe NAS, reduce pollution, and provide significant benefits tothe economy. Notably, the benefits ofCoeus'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 OfThe NAS.The DJI Phantom 2 Vision+, Phantom 3 Professional UA are battery powered and serve as asafe, efficient, and economical alternative tothe manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount ofmanned aircraft needed to perform aerial acquisitions, an exemption allowingthe use of

a DJI Phantom 2Vision+, 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. 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 2 Vision+, Phantom 3 Professional UA do not require

an airport totakeoffor land. likewise, a reduction ofmanned aircraft conducting aerial video and photography missions would result in fewer aircraftthat must be handled byairtraffic control duringthe ground, takeoff, departure, arrival, and landing phases offlight operations. 2. The Public Will Benefit From The Safety And Efficiency OfThe DJI Phantom 2 Vision+, Phantom 3 UAS. Conducting aerial acquisitionswith the DJI Phantom 2 Vision+, Phantom 3 Professional UAS, instead of manned aircraft, will greatly benefitthe public by drastically reducingthe levels ofairand noise pollution generated during-----·--------------------------

traditional aerial video and still photographyflight operations. By using battery power and electric**motor~** the 

### OJI Phantom 2Vision+, Phantom 3 Professional UAS produce no air pollution, and is the mostviable environmentally conscious · alternativeto the cabin class, six cylfnder 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 

### OJI Phantom 2 Vision+, Phantom 3 Professional UA, while reducingthe carbon footprint of aerial acquisitions, also eliminates. noise pollution, as the UAS are propelled by battery powered electric motors, ratherthan an internal combustion engine. By usingthe 

### OJI Phantom 2Vision+, Phantom 3 Professional UAS to perform aerial acquisitions, thesubstantial riskto life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced orcompletely eliminated. Aside from the lack offlight

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, attheir 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 potentialfor collateral damage to life and propertyon the ground, and in the air, compared tothe manned aircraft thattypically conduct similar operations (weighing approximately 6,000 pounds with awingspan ofapproximately 42 feet, a length of34feet, and afuel capacity of 180 gallons). 3. Performing Aerial Video and Photography Operations WithThe 

### DJI Phantom 2 Vision+, Phantom 3 UAS Will BenefitThe Economy. In additionto being safe and efficient, the 

### DJI Phantom 2 Vision+, Phantom 3 Professional is also an economical alternative to using manned aircraftto conduct similar aerial operations. As such, operation ofthe 

### OJI Phantom 2 Vision+, Phantom 3 Professional UAS will allow United States based companies, like Over Exposure, to remain competitive and contributeto growth ofthe U.S.economy. Specifically, with the rising cost ofaviation 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 orderto remain competitive. Operatingthe battery powered DJI Phantom 2 Vision+, Phantom 3 Professional UAS is one such technologythat not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility withoutthe high operational cost of atraditional manned aircraft. By operatingthe DJI Phantom 2 Vision+, Phantom 3 Professional UAS, companies such as Coeus, can remain competitive and profitable, and therefore, provide greaterjob stabilityto employees and contractors, which will ultimately contribute to growth ofthe 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, state, and federal tax revenues; and allowstompaniesto invest in research and development in orderto remain competitive both in the United States and abroad. 4. There Are No Privacy Issues. Similartothe manned aerial acquisition flight operations that have been conducted for decades, Coeus proposed operation ofthe DJI Phantom 2Vision+, Phantom 3 UAS will not implicate any privacy issues. Specifically, the DJI Phantom 

### 2Vision+, Phantom 3 Professional UAS will be operated only in compliance with operating documents (i.e., the Coeus Aerial Operations Manual, MonthlyMaintenance 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 accordance with the Federal Aviation Regulations, includingthe minimumaltitude requirements of 14 C.F.R. § 91.119. · E. The Reasons Why Granting The Exemption Would NotAdverselyAffectSafety, OrHow The Exemption Would Provide A Level OfSafetyAtLeastEqual To That Provided By The Rule From Which Coeus Seeks Exemption.1. Reasons WhyThe DJI Phantom 2Vision+, Phantom 3 Professional UAS Meet The Conditions OfThe FAA Modernization and Reform Act of2012 (FMRA) Section 333. In consideration ofthe

## size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Coeus operation ofthe

### DJI Phantom 2 Vision+, Phantom 3 Professional UAS meetthe 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 authorityfor a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, or otherwise pose athreatto national security. Specifically, FMRA Section 333 states the following, in part: (a) In GeneraL--Notwithstanding any other requirement ofthis subtitle, and not laterthan 180days

**a~er** the date of enactment ofthisAct, the Secretary of Transportation shall determine ifcertain unmanned aircraft systems may operate safely in the national airspace system before completion ofthe plan and rule-making required bysection 332 ofthis Act orthe guidance required by section 334 ofthis Act. {b) Assessment of Unmanned Aircraft Systems.--ln makingthe determination undersubsection (a), theSecretary shall determine, at a minimum-- (1) which types of unmanned aircraft systems, ifany, as a result oftheirsize, weight, speed, operational capability, proximityto airports arid populated areas, and operation withinvisual line ofsight do·notcreate

a hazard to users ofthe national airspace system orthe publicor pose athreatto national security; and (2) whethera certificate ofwaiver, certificate ofauthorization, or airworthiness certification undersection 44704 oftitle 49, United States Code, is required for the operation ofunmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.--lfthe Secretary determines underthissection that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system. In seekingthis exemption, Coeus submits thatthe DJI Phantom 2 Vision+, Phantom

# 3Professional UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics ofthe DJI Phantom 2 Vision+, Phantom 3 Professional UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.



### a. The SpecificationsOfThe OJI 

### Phantom 2Vision+, Phantom 3 Professional UAS Demonstrate Its Safe Characteristics. The DJI Phantom 2Vision+, Phantom 3 Professional UAS doesnotcreatea hazardtousersoftheNAS orthepublic,

orotherwise posea threattonational securityconsideringits size, weight, speed,and operationalcapability. i. Technical Specifications OfThe DJI Phantom 2 Vision+, Phantom 3 Professional

. UAS. The technical specifications ofthe DJI Phantom 2 Vision+, Phantom 3 Professional UAS is setforth bythe 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 manual and fully autonomous flight modes. A complete description of

the flight and navigational modes ofthe DJI Phantom 2 Vision+, Phantom 3 UAS is provided at pages 25-35 ofthe 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 similarto DJI Phantom 2 Vision+ User Manual). iii. The DJI Phantom 2Vision+, Phantom 3 Professional UAS Are Designed For Automatic Return To Home Point Or Hover In The Event Of loss OfThe 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 linkdata from the GCS, the UA will assume thatthe Control link is lost and the UAwill return to the home position (i.e., failsafe mode) via GPS, and will descend tothe takeoff position and shutdown. A complete description ofthe Failsafe Functions ofthe DJI Phantom 2 Vision+, Phantom 3 Professional UAS are set forth at pages 27 through 29 ofthe DJI Phantom 2 Vision+, (Phantom 3) Professional User Manual, attached hereto as B

### & D. iv. The DJI Phantom 2Vision+, Phantom 3 Professional GCS And Its Operation. A complete description ofthe operation and specifications ofthe DJI Phantom 2 Vision+, Phantom 3 GCS and flight control software is provided at pages 32 through 43 ofthe DJI Phantom 2 Vision+, (Phantom 3) Professional User Manual. DJI Phantom 2 Vision+ User Manual is attached hereto as Exhibit B 

### & D. 

### b. Flight OperationsOf

### DJI Phantom 2 Vision+, Phantom 3 Professional UAS Are Limited To The Line OfSight OfACertificated Pilotin CommandWithASafety Observer. Coeus will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) ofthe DJI Phantom 2 Vision+, Phantom 3 Professional UAS. Additionally, a safety observerwill assist all pilots duringflighttime.



### c. Flights OfDJI Phantom2 Vision+, Phantom 3 Professional UAS Will Be Conducted PursuantTo Specific OperatingLimitations. In seekingthis exemption, proposes to commercially operate DJI Phantom 2 Vision+, Phantom 3 Professional UAS forthe special purpose ofconducting aerial video and photography over certain areas of United States, pursuantto the following specific operating limitations:



### 1. Operations authorized·bythis 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 

### 2Vision+, Phantom 3 Professional Unmanned Aircraft System. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.



### 2. UAS operations underthis exemption will be limited to conducting operations forthe purpose of aerial video and photographyfor 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 forfilm and television sets, special events 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 ofno morethan 200 (500 perthe User Manual)feetabove ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved byATC. All altitudes reported toATC must be in feet AGL. · 5. The UAS must be operated within visual line ofsight (VLOS} ofthe PIC at all times. This requires the PIC to be able to use human vision unaided by any device otherthan corrective lenses, as specified on the PIC's FAA-issued airman medical certificate. 6. The use offirst person view (FPV) bythe PIC or safety observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be used to satisfythe VLOS requirement as 1ong as the PIC always maintains VlOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging ortexting is not permitted duringflight operations. The PIC must be designated before theflight and cannottransfer his or herdesignation fortheduration oftheflight. 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 airtraffic and otherground based obstacles/obstructions and is not permittedto operatethe camera orother instruments. 9. The operating documents and the grant ofexemption must be accessible during UAS operations and made available tothe Administrator upon request. If

a discrepancy exists between the conditions and limitations contained in the grant ofexemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grantof exemption take precedence and must be followed. Otherwise, the operator mustfollowthe procedures as outlined in its operating documents. The operator may update or revise its operating documents. Itis the operators responsibilitytotrack such revisions and present updated and revised documents tothe Administrator upon request. The operator must also present updated and revised documents if it petitions for extension oramendmenttothe grant of.exemption. Ifthe operatordetermines that any update or revision would affect the basis upon which the FAA granted the exemption, thentheoperator must petition for amendmentto its grant of exemption. The FAA's UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions tothe operating documents. 10. Priorto each flightthe PIC must inspectthe UAS to ensure that it is in a condition forsafe flight. Ifthe inspection reveals a condition that affects the s.afe operation ofthe UAS, the aircraft is prohibited from operating untilthe necessary maintenance has been performed and the UAS is found to be in a condition forsafe 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 alterationsthat affectthe UAS operation orflight characteristics, e.g. replacement ofaflight critical component, must undergo afunctional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records. 12.The pre-flight inspection must accountfor all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections ofthe operating documents. 13.The operator must followthe 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, inaccordance 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 ofwork accomplished, and the signature ofthe authorized person returningthe UAS to service. 15. Each UAS operated underthis exemption must complywith all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record ofthe corrective action taken against discrepancies discovered between inspections. 17.The PIC must possess at least a Supplemental Pilot certificate and at least a currentthird- class medical certificate. Supplemental pilots must have,at a minimum, 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, orairline transport pilot knowledge testwithin 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 demonstratesthe abilityto safely operate the UAS in a manner consistent with how the UAS will be operated underthe exemption, including evasive and emergency maneuvers and maintainingappropriate distances from persons, vessels, vehicles and structures. PIC qualificationflight hours must be logged in a mannerconsistent with 14 C.F.R. § 61.51(b). Flights forthe purposes oftrainingthe operator's PICs are permitted undertheterms ofthe exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons notessential forflight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14C.F.R. § 91.119. 19. UAS operations may not be conducted during night, as defined in 14C.F.R. 

### § 1.1. All operations must be conducted undervisual meteorological conditions (VMC). Ifflight at night is required, a special**n~quest** will be made atthe FAA office closest to proposed area ofoperations. Flights underspecial visual flight rules (SVFR) are notauthorized. 20. The UA may notoperate within 5 nautical miles ofan airport reference point

as denoted on a current FAA-published aeronautical chart unless a letterof agreement withthat airport's management is obtained, and the operation is conducted in accordance with a NOTAM as-required by the operator's COA. The letterofagreement withthe airport management must be made available tothe Administrator upon request. 21. The UA may not be operated less than 500 feet belowor less than 2,000 feet horizontallyfrom a cloud orwhen visibility is less than 3 statute miles from the PIC. 22. Ifthe 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 aborttheflight in the event of unpredicted obstacles or emergencies in accordance withthe operating documents. 24. The PIC is prohibited from beginning aflight unless (considering wind and forecast weather conditions) there is enough powertofly at normal cruisingspeed tothe intended landing point and land the UA with 25% battery power remaining. 25. The operator must obtain an AirTraffic Organization (ATO) issued Certificate ofWaiver orAuthorization (COA) priorto conducting any operations underthe grant ofexemption. This COA will also require the operatorto request a Notice to Airman (NOTAM) not morethan 72 hours in advance, but not less than 48 hours priorto the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class ofairspace, altitude level and potential transponder requirements. 26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordancewith 14 C.F.R. part

### 47, and have identification (N- Number) markings in accordance with 14 C.F.R. part45, Subpart C. Markings must be as large as practicable. 27. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewerthan 14 C.F.R. 91.9 and 91.203 must be available tothe PIC atthe Ground Control Station ofthe UAS any time the UAS is operating. These documents must be made available tothe Administrator or any law enforcement official upon request. 29. The UAS must remain clear and yield the right ofway to all manned aviation operations and activities at all times. 30. The UAS may not be operated bythe PIC from any moving device orvehicle. 31. Flight operations must be conducted at least 500 feetfrom all nonparticipating persons (persons otherthan the PIC, SO,**op~rator** trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers orstructures are presentthat sufficiently protect nonparticipating persons from the UA and/or debris in the event ofan accident. The operatormustensure that nonparticipating persons remain undersuch protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated nearvessels, vehicles orstructures wherethe owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk ofoperatingclosertothose objects and determinedthat it does not present an undue hazard, and;

c. Operations nearerto the PIC, SO, operatortrainees oressential persons do not present an undue hazard tothose persons per§ 91.119(a). 32. All operations shall be conducted over private orcontrolled-access property with permission from the land owner/controller or authorized representative. Permission from land owner/controlleror authorized representative will be obtained for each flight to be conducted. 33. Any incident, accident, orflight operation thattransgresses the lateral or vertical boundaries ofthe operational area as defined bythe applicable COA must be reported tothe FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported tothe National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. 2. Reasons WhyAn Exemption FromThe Requirements OfSection 61.113(a) And (b) Would NotAdverselyAffect Safety. Coeus submitsthatthe equivalent level ofsafety established bySection 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 demonstrated, by meeting minimum flight- hour and currency requirements, thatthe PIC is able to safely operatethe DJI Phantom 2Vision+, Phantom 3 Professional UAS in a mannerconsistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.Considering Coeus proposed area ofoperations, and the operating limitations set forth-above; the parallel nature of private pilot aeronautical knowledge requirements tothose ofcommercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operatethe DJI Phantom 2 Vision+, Phantom 3 Professional UAS, Coeus submitsthatthe additional manned airmanship experience ofacommercially certificated pilotwould notcorrelate to the airmanship skills necessary for Coeus specific proposed flight operations. The FAA has previously granted relieffrom Section 61.113(a} and (b) specific to UAS, in circumstances similar, in all material respects, tothose 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}. 3. Reasons WhyAn Exemption From The Requirements OfSection 91.7{a) Would NotAdverselyAffectSafety. The equivalent level ofsafety established by Section 91.7(a} will be maintained because priorto every flight, Coeus will ensure thatthe OJI Phantom 2 Vision+, Phantom 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 relieffrom 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 WhyAn Exemption From The Requirements OfSection 91.121 Would NotAdverselyAffect Safety. The equivalent level ofsafety established by Section 91.121 will be maintained because the altitude information ofthe DJI Phantom 2 Vision+, Phantom 3 Professional UA will be provided tothe PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCSfor active monitoring oftheflight path and altitude. This aititude information, combined with Coeus's operation ofthe OJI Phantom 2Vision+, Phantom 3 Professional UAS within visual line ofsight, at or below 500 feet AGL, will ensure

a level ofsafety equivalentto Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Priorto each flight, a

zero altitude initiation point is automatically established bythe UASs at ground level. The FAA has previously granted relieffrom 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,**1111~11136,11138,11150, 11153,1115~11157,11158,11159,**  11160, 11161). 5. Reasons WhyAn Exemption From The Requirements OfSection 91.151{b) Would NotAdversely Affect Safety. A grant ofthis exemption would ensure an equivalent level ofsafety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications ofthe DJI Phantom 2 Vision+, Phantom 3 Professional UAS; (2) the limitations on the proposed flightoperations; and (3) the location ofthe proposed flight operations. Accordingly, Coeus will ensure that itwill safely operatethe battery powered DJI Phantom 2Vision+, Phantom 3 Professional UA during daylight hours in VFR conditions, with enough battery powertoflyfor atotal duration of 13.5 minutestothe first point of intended landing and, assuming normal cruising speed, tofly afterthatfor at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications ofthe OJI Phantom 2Vision+, Phantom 3 Professional UAS; the limitations on the proposed flight operations; and the location ofthe proposed operations, will ensure an equivalent level ofsafety 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 tothe PIC atthe GCS whenthe UAS experiences low batteryvoltage, thefirst warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. Atthe 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 thetechnical characteristics and operating limitations ofthe UAS are considered. Relief has been granted for manned aircraftto operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relieffrom 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 WhyAn Exemption From The Requirements OfSections 91.405(a), 91.407(a)(l), 91.409(a)(l) 

### & (a}(2}, And 91.417(a) 

### & (b) Would Not Adversely Affect Safety. In seeking this exemption, Coeus submits thatthe equivalent level of safety with regard tothe 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 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 Manual). Furthermore, Coeus will document and maintain all maintenance records forthe DJI Phantom 2 Vision+, Phantom 3 Professional UAS. Since the DJI Phantom 2Vision+, Phantom 3 Professional UAS will be inspected

as prescribed by the operating documents, Coeus will maintain**t~e** equivalentlevel ofsafety established by Sections 91.405(a}, 91.409(a}(1}, and 91.409(a}(2}. A copy ofthe DJI Phantom 2Vision+ User Manual is attached hereto as Exhibit B 

### & D; acopy ofthe DJI Phantom 2Vision+, 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 maintenance on theUAS using the methods, techniques, and practices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level ofsafety established by Sections 91.407, 91.417(a} and 91.417(b}, because all maintenance ofthe DJI

. Phantom 2Vision+, Phantom 3 Professional UAS will be performed by trained

technicians. Maintenance will be documented and maintained utilizingthe 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 thetechnical characteristics and operating limitations.ofthe UAS are considered. In consideration of Coeus proposed operating limitations, the operating documents, and thetechnical aspects ofthe DJI Phantom 2 Vision +, Phantom 3 Professional UAS, Coeus 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, tothose 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 ofthe FAA Modernization and Reform Act of 2012 (FMRA} and 14C.F.R. § 21.16 entitled Special Conditions, Coeus requests thatthe FAA prescribe special conditions forthe intended operationofthe DJI Phantom 2Vision+, Phantom 3 Professional UAS, which contain such safetystandards thatthe Administratorfinds necessaryto establish a level ofsafety equivalent tothat 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 ofthe UAS forthe limited purpose of conducting aerial video and photography

over certain areas ofthe United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, or otherwise pose athreatto national security; and further, provides the authorityfor such UAS to operate without airworthiness certification in accordance with any requirements that must be established forthe safe operation ofthe UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation ofthe 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, dueto the novel or unusual design features ofthe aircraft. Section 21.16, entitled Special Conditions, statesthe following: Ifthe FAA finds thatthe airworthiness regulations ofthis subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine,

or propeller because ofa novel or unusual design feature ofthe aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto forthe product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards forthe aircraft, aircraft engine or propeller as the FAA finds necessary to establish a levelofsafety 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 

### Coeus's intended operation ofthe DJI Phantom 2 Vision+, Phantom 3 UAS, which contain such safety standards that theAdministratorfinds necessary to establish a level ofsafety equivalentto thatestablished by 14C.F.R. Part 21, Subpart H, and 14C.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 SummaryThat Can Be Published InThe Federal Register, stating:The Rules From Which Coeus Seeks Exemption: 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 OfThe Nature OfThe Exemption Coeus Seeks: This exemption will permit Coeus to commercially operate an Unmanned Aircraft System (UAS) for the purpose ofconducting aerial video and photography over certain areas ofthe United States. G. AnyAdditional Information, Views, OrArguments AvailableTo Support UAV Aerial Video Request. · This Petition is made pursuantto the FAA Modernization and Reform Act of2012 (FMRA) Section 333, which directs the Secretary ofTransportation to determine ifcertain UAS may operate safely in the NAS. As such, Coeus requestfor exemption may be granted pursuant to the authority of FMRA Section 333 and 14C.F.R. Part 11, as setforth above. FMRA Section 333 sets forth the requirementsfor considering whether a UAS will create a hazard to users ofthe NAS orthe public, or otherwise pose athreatto national security; and further, provides the authorityfor such UAS to operate without airworthiness certification. As discussed in detail above, Coeus will operate the DJI Phantom 2 Vision +, Phantom 3 Professional UAS safely in the NAS, without creating a hazard to users ofthe NAS, orthe public, or otherwise pose athreatto 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 and Reforni Act of2012 (FMRA), which will permit safe operation ofthe

### DJI Phantom 2 Vision+, Phantom 3 Professional UAS commercially, without an airworthiness certificate, forthe limited purpose ofconducting aerial video and photography overcertain

areas ofthe United States. By grantingthis Petition, the FAA Administrator will be fulfillingthe Congressional mandate ofthe FAA Modernization and Reform Act of2012, while also advancing the interests ofthe public, by allowing UAV Aerial Video to safely, efficiently, and economically operate the 

### OJI Phantom 2 Vision+, Phantom 3 Professional UAS commercially within the NAS.

WHEREFORE, in accordance withthe Federal Aviation Regulations and the FAA Modernization and Reform Act of2012, Section 333, Coeus respectfully requests thatthe Administrator grant this Petition foran 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 operatethe 

### DJI Phantom 2 Vision +, Phantom 3 Professional UAS commercially forthe purpose ofconducting aerial video and photography of Real Estate Properties (for homeowners, realtors, home builders, home contractors and 

## I or home inspectors for real estate marketing and inspection ofhome 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 ofthe United States.

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 2Vision+ Manufacturer's User Manual C- DJI Phantom 3 Professional Specifications Data Sheet 0- DJI Phantom 3 Manufacturer's User Manual E- Monthly Maintenance LogAPPENDIX-A DJI PHANTOM 2VISION+ 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 enablingthe userto set parameters which will not allowflight into controlled airspace. Parameters can also be set to limitflight to no higher than a predetermined and set altitude as well as limitflight to a predetermined and set distance. In addition, DJI software provides real-time altitude and location information tothe PIC via the linked monitor (smart phone/tablet devices).

1.1 DJI Phantom 2Vision+ 1.1.1 Aircraft 1.1.1.1 Supported Battery- DJI 5200mAH LiPo Battery 1.1.1.2 Weight (Battery 

### & Propellers Included)- 21bs 11.810oz (1242g) 1.1.1.3 HoverAccuracy (Ready to Fly)- Vertical: .8m; Horizontal: 2.Sm 1.1.1.4 MaxYaw Angular Velocity- 200°/s 1.1.1.5 MaxTiltAngel- 35° 1.1.1.6 MaxAscent 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° 1.1.2.3 Controllable Range- Pitch: -90°-0° 1.1.2.4 Maximum Angular Speed- Pitch: 90°/s 1.1.3 Camera 1.1.3.1 OperatingTemperature Range- 32°F- 104°F (0°C- 40°C) 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 ofView- 110°/85° 1.1.4Transmitter 1.1.4.1 Operating Frequency- 5.728GHz- 5.85GHz 1.1.4.2 Communication Distance (unobstructed)- FCC Compliance: BOOm 1.1.4.3 Receiver Sensitivity (1%PER)- -93dBm 1.1.4.4Transmitter Power- FCC Compliance: lOOmW

### 1.1.4.5 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 1.1.5.3Transmitter 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 BatteryAnd Propellers) Diagonal Size (Including Propellers) MaxAscent Speed Max Descent Speed HoverAccuracy

• Vertical: +/- 10cm

• Horizontal: +/-1m MaxSpeed MaxAltitudeAbove Sea Level OperatingTemperature Gps Mode GIMBAL Controllable Range Stabilization REMOTE CONTROLLER Operating Frequency Max Distance Video Output Port OperatingTemperature Battery Mobile Device Holder Sensitivity (1%Per) Transmitter Power (Eirp)

• FCC: 20 dBm

• CE: 16 dBm WorkingVoltage 1280g 590mm 5 m/s 3 m/s

16 m/s (ATTI 

### mode, no wind) 6000m 

# ooc to 40°C GPS/GLONASS

Pitch -90° to +30° 3-axis (pitch, 

### roll, yaw)

2.400 GHz-2.483 GHz 2000m (outdoors/unobstructed) USB 0°C- 40°C 6000 mAh LiPo 2S For tablet or phone Receiver -101 dBm ±2 dBm

1.2 A @7.4 VBATTERY CHARGER Voltage Phantom 3 Professional

INTELLIGENT FLIGHT BATTERY Capacity Voltage BatteryType Energy NetWeight Max FlightTime OperatingTemperature Max Charging Power 

### 17.4V Rated Power 100W

4480 mAh 

### 15.2

# v LiPo 

### 4S 68Wh 

### 365 

### g Approximately 23 

### minutes -10°C to 40°( 100W•" • •**~** _.;._. t

.

APPENDIX-D DJI Phantom 3 Professional Manufacturer's User Manual (uploaded in a separate attachment, a58-page document)UAS 

### # Software Updates Airframe Engines Propellers CameraGimbal Landing Gear Vibration Dampening Other: 

### APPENDIX-E MONTHLYMAINTENANCE LOG

DateIssue Date Issue .Issue Description Discovered Addressed 

### &Maintenance Conducted Maintenance PerformedBy: Print 

### & Sign