August 20, 2015

U.S. Dept. of Transportation, Docket Operations West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, SE., Washington, DC 20590

Dear Administrator:

Coptergraphics PR would like the Federal Aviation A dministration (FAA) to consider this letter as its formal Section 333, Wai ver and Exemption. As a leader in the digital photography, television and cinematic i ndustries. (CGPR) caters to a wide variety of photographic needs required to support o f its clients, both private and

commercial.

In accordance with Section 333 of the FAA Moderniza tion and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Coptergra phics PR an operator of Unmanned Aircraft Systems (“UASs”) for aerial photo graphy and video on the real estate industry, surveying, agriculture industry, c onstruction industry, motion picture industry, television industry and special e vents, hereby applies for an exemption from the Federal Aviation Regulations (“F ARs”) to allow commercial operation of its UASs, so long as such operations a re conducted within and under the conditions outlined herein or as may be establi shed by the FAA as required by

Section 333.

The specific section or sections of 14 C.F.R from w hich Coptergraphics PR seeks exemption: (CGPR) seeks exemption from applicable title 14 Cod e of Federal Regulations (CFRs) relevant to small Unmanned Aircraft System (sUAS), as defined by the FAA, operations. The below list, includes but is not lim ited to, regulations limiting sUAS operations.

1. 14 CFR Part 21, Subpart H: Airworthiness Certificat es.
2. 14 CFR 91.203(a) & (b) Civil aircraft: Certificatio ns required.

3. 49 USC § 44711 Prohibitions and exemption

4. 14 CFR 45.23 Display of Marks; General and 45.29 Si ze of Marks.

5. 14 CFR 91.9 Civil Aircraft Flight Manual, Marking, and Placard Requirements.

6. 14 CFR 91.119 Minimum Safe Altitudes.

7. 14 CFR 91.121 Altimeter Settings.

8. 14 CFR 91.151 Fuel Requirements for Flight in VFR C onditions.

9. 14 CFR Subpart E (91.401 - 91.417) - Maintenance, P reventive Maintenance,

and Alterations.

10. FAA Notice 8900.227 Paragraph 16(c) (4) PIC Medical and Paragraph 16(e)(1) Observer Medical

. 

### Coptergraphics PR

HC 02 Box 15710 Gurabo, Puerto Rico 00778Coptergraphics PR is requesting relief from multipl e regulatory constraints under

title 14 CFR Parts 21, 45, 61, 65, 91 as well as ot her UAS regulatory guidance under FAA Notice 8900.227, Public Law 112- 95, Title 49 U nited States Code (USC), with regards to Unmanned Aircraft System (UAS) operation s, more specifically sUAS commercial operations.

An exemption is being requested because (1) Copterg raphics PR can provide a level of safety that is equal (or greater than in many ca ses) to those provided by existing rules, and (2) the request is in the public interes t. The FAA’s authority to issue exemptions from operating rules, and the Secretary’ s authority granted by Section 333 of P.L. 112-95, Special Rules for Certain Unman ned Aircraft Systems, provide an opportunity to authorize certain UAS operations in the National Airspace System (NAS) prior to implementation of the UAS rule. Thi s incremental step and opportunity will allow Coptergraphics PR to safely and legally enter into the NAS.

The requested exemption would permit Coptergraphics PR to operate UASs under controlled conditions in airspace that is (1) limit ed; (2) predetermined; (3) subject to controlled access, and (4) would provide safety enhancements to the already safe operations of those aircraft of similar size, weigh t, speed, and operating capability that have been granted entry into the (NAS) via the rules in Academy of Model Aeronautics (AMA) Code.

Photos and Videos from several angles and height ar e far more effective than ground- based imagery for displaying the characteri stics of large, complex properties with several buildings where helicopters cannot reach. It is known that charting a 2 seat full-sized helicopter or airplane for this purpose, has proven very costly and has limitations. The benefits of reduce d cost, reduced noise interference, safety and improved quality of presentation from th e UASs will be valuable to and benefit many real estate industry, agriculture indu stry, construction industry, motion picture industry, television industry, surve ying and special events. The site based photography occurs in restricted or other are as where access to the public is strictly limited and controlled. Under virtually a ll circumstances, all of the only property or structures near the sites are owned and operated by the same entity soliciting the aerial photography services. As a r esult, the operation has no substantial impact on any third persons not involve d in the actual site project. As established by the exemptions already granted by th e FAA, approval of Coptergraphics PR exemption would enhance safety, n ew windows of opportunities and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 3 33(c) of the Reform Act.

Operation OverviewUASs operated by Coptergraphics PR weigh less than 10 pounds, including the

payload (first person view system, camera and gimba l). They operate at speeds of no more than 30 knots, can hover, and can simultane ously move vertically and horizontally. Coptergraphics PR will only operate its UASs in line of sight (VLOS) and will operate only within the operation manuals and authorize airspace. They will routinely be operated below 200 feet above gro und level (AGL), and never about 400 feet AGL. Operations will always be condu cted in areas that are clear of all people, except the pilot in command (PIC), PIC’ s helper(s) or/and production crew. Such operations will insure that the UAS wil l “not create a hazard to users of the national airspace system or the public.”

Given the small size of Coptergraphics PR’s UAS and the restricted sterile environment within which they will operate, Copterg raphics PR UAS operations adhere to the Reform Act’s safety requirements. Ad ditionally, due to the size of the UASs and the limited areas in which they will opera te, approval of this application presents no national security issues. Based on the substantial level of safety surrounding the proposed operations, and the signif icant public benefit (enhanced safety), reduction in environmental impacts (reduce d emissions and noise), the grant of the requested exemption is in the public i nterest. Accordingly, Coptergraphics PR, respectfully requests that the F AA grant the requested exemption without delay.

Aircraft

Coptergraphics PR operates a Tarot 680 PRO and Insp ire 1 series manufactured by DJI, as well-known leader in multirotor technology industries. DJI strives to bring new perspectives to aerial work and help companies accomplish feats safer, faster, and with greater efficiency. They have an unparall eled commitment to quality and safety, a culture of constant innovation, and a foc us on transforming complex technology into easy-to-use devices. The Tarot mul tirotor package includes, camera, gimbal, propulsion system, flight control s ystem, 2.4 GHz frequency remote

controller.

The Tarot is about 2 foot square in size. It has a maximum ascent speed of 11 knots, a maximum descent speed of 3 knots, and a maximum f light speed of 29 knots. While operating within VLOS, the remote control has a range of 2,624 feet. The total weight (including the payload) is 7.50 pounds.

The Tarot 680 Pro is equipped with a DJI Naza-M V1 flight control system. This provides for incredible ease of use and stability. Pilots can control the Tarot’s movements in many directions – including pitch (for ward and backward), roll (left and right), elevator (up and down), and yaw (turn l eft or right). The flight control system can also provide Intelligent Orientation Con trol (IOC), failsafe, battery level warnings, and with the on screen display system (OS D) shows to the pilot incommand (PIC) the aircraft’s current reading, direc tion, and approximate distance

from home on the on-screen radar, battery voltage, altitude, distance. The built-in GPS system aids in stabilizing the aircraft and aut omatically and safely returns it back to its home point in any case where communicat ion between the remote

control and multirotor are lost.

The Inertial Measurement Unit (IMU) has a built-in inertial sensor and a barometric altimeter that measures both attitude (ATTI) and al titude. The inertial

measurement tells the Phantom how it’s tilted. And the gyros tell it if it’s rotating in any particular direction.

The Tarot’s compass read geomagnetic information an d assist the Global Positioning System (GPS) to accurately calculate the position a nd height of the aircraft. The vertical hover accuracy is +/- 2.6 ft. The horizont al hover accuracy is +/- 8.2 ft.

The Tarot has LED flight indicators beneath each of its six rotor arms. The LEDs

illuminate to indicate the orientation of the UAS. The status of the flight control system alert the (PIC) of any possible issues via e stablished light codes are displayed by another led beneath the body of the UA V so it can be seen on the fly.

The Tarot’s DJI Naza software has the capability to be upgraded via USB in a computer to enhanced performance with the latest so ftware or firm available on DJI

website.

Such highly advanced capabilities will ensure that the SUASs can be safely operated and “not create a hazard to users of the n ational airspace system or the public.” As per Reform Act Section 333 (b).

Equivalent Level of Safety

Detailed below is a list of operational safeguards Coptergraphics PR believes are essential for safe operations of which many have be en previously approved by the Administer for similar sUAS operations. In addition , Coptergraphics PR will not commence sUAS operation that will create an undue h azard to users of the national airspace system (NAS), the public, or pose a threat to national security. Coptergraphics PR has published and/or adopted the following documents to be an integral part of its sUAS operations. Flight Operations Manual (Flight Ops Manual) Motion Picture and Television Operations Manual (MP TOM) DJI Published

User Manuals

Maintenance Manuals Safety Guidelines

The operating limitations proposed by Coptergraphic s PR provide for at least an equivalent or higher level of safety. In an effort to join the FAA in its mission toprovide the safest, most efficient aerospace system in the world and to minimize the

risk to the NAS or to persons and property on the g round. As a member of AMA (Academy of Model Aeronautics) member #949590, Copt ergraphics PR agrees to be bound by the following limitations and conditions w hen conducting commercial operations under an FAA issued exemption as set for th in operator’s manual and UASs will be operated within the standards that the FAA has allowed in the Academy of Model Aeronautics (AMA) Safety Code:

1. The UASs will weigh less than 55 pounds.

2. Will not be flown in a careless and reckless manner

. 3. Will not be flown at a location where UASs activiti es are prohibited.

4. Flights will be operated within line of sight of a pilot and/or observer.

5. Maximum flight time for each operational flight wil l be 25 minutes. Flights will be terminated at 25% battery power reserve and will occur prior to the 25 minute limit at about 15 minute flight time.

6. Flights will be operated at an altitude of no more than 400 feet AGL, and not more than 200 feet above an elevated platform from which filming is planned.

7. Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer, and the production staff.

8. A UAS Pilot will be Pilot in Command (PIC). If a pi lot certificate holder other than the UAS Pilot, who possesses the necessary PIC qualifications, is also present on set, that person can also be designated as PIC.

9. A briefing will be conducted for planned UAS operat ions prior to each day’s flight. All personnel performing duties within the boundaries of the safety perimeter are required to attend.

10. The operator will file a FAA Form 7711-1, or its eq uivalent, as modified in light of the requested exemption, with the appropri ate Flight Standards District Office (”FSDO”).

11. The operator will obtain consent of all persons inv olved in the filming and ensure that only consenting persons will be allowed within 100 feet of the flight operation. With the advanced permission of t he FSDO, operations at closer range can be approved.

12. The operator will submit a written Plan of Activiti es to the FSDO three days before the proposed shoot.

13. The Pilot and observer must be trained in UAS opera tions and have received current information on the particular UAS to be ope rated.

14. The Observer and pilot will at all times be able to communicate by voice and/or visual signals.

15. Written and/or oral permission from the relevant pr operty holders will be

obtained.

16. All required permissions and permits will be obtain ed from territorial, state, county, or city jurisdictions, including local law enforcement, fire, or otherappropriate governmental agencies.

17. If the UAS loses communications or loses its GPS si gnal, the UAS will have the capability to return to a pre-determined location w ithin the Security

Perimeter and land.

18. The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies. 14 C.F.R. § 61.113(a) and (b): Private Pilot

Preflight Action Plan

The PIC will follow a comprehensive pre-flight chec klist to ensure that the UAS is in a condition for safe flight. This plan will be imp roved as needed in order to ensure all known safety precautions and/or safety precauti ons suggested by the manufacturer are being accounted for.

Preventative Maintenance

Comprehensive preventative maintenance plan will be followed in order to ensure the UAS’s software is up-to-date, the batteries are in good health, and the aircraft itself is always ready for safe flight.

Privileges and Limitations:

Pilot in Command Sections 61.113 (a) and (b) limit private pilots to non-commercial operations. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safe ty of current operations by requiring the (PIC) operating the aircraft to have a sport pilot license rather than a commercial pilot’s license to operate a small UAS. Unlike a conventional manned aircraft, a UAS is remotely controlled by a ground- based operator. The operational area is controlled and restricted, and all flights are planned and coordinated in advance. The level of safety exceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventi onal aircraft. The risks associated

with the use of a UAS are so diminished from the le vel of risk associated with commercial operations contemplated by Part 61 allow ing UAS use by a private pilot as the (PIC) exceeds the present level of safety so ught by 14 C.F.R. §61.113 (a) and (b). 14 C.F.R. § 91.103: Preflight Action Section 9 1.103 requires each pilot to preflight an aircraft before flight to insure the s afety of flight. As FAA approved rotorcraft flight manuals will not be used, an exem ption is requested. However, an equivalent level of safety will be provided. The ( PIC) will take all actions, including reviewing weather, flight battery requirements, lan ding and takeoff distances, and aircraft performance data before commencement of fl ight.

14 C.F.R. §91.119(c): Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for opera tion of civil aircraft. Section91.119 provides, in pertinent part, that: “except w hen necessary for takeoff or

landing, no person may operate an aircraft below th e following altitudes: .....

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.”

Because Coptergraphics PR requests authority to ope rate at altitudes only up to 200 feet and never above 400 feet, and not more than 20 0 feet above an elevated platform from which filming is planned, an exemptio n is needed to allow such operations. The UAS will never operate higher than 400 AGL. It will, however, be operated in a restricted area within a security per imeter, where buildings and people will not be exposed to operations without th eir pre-obtained consent.

The equivalent level of safety will be achieved giv en the size, weight, and speed of the UAS as well as the location where it is operate d. No flight will be taken without the permission of property owners or local official s. Because of the advance notice to the property owners and participants in the film ing activity, all affected individuals will be informed of the planned flight operations. Compared to flight operations for manned aircraft and the lack of flam mable fuel, any risk associated with the proposed UAS operations is far less than c onventional aircraft operating at or below 500 AGL. In addition, the low-altitude op erations of the UAS will ensure separation between a UAS and conventional aircraft.

14 C.F.R. §91.121 Altimeter Settings

Section 91.121 requires each person operating an ai rcraft to maintain cruising altitude by reference to an altimeter that is set “ ...to the elevation of the departure airport or an appropriate altimeter setting availab le before departure.” As a UAS may not have a barometric altimeter, but instead a GPS altitude data, an exemption is needed. An equivalent level of safety will be a chieved by the operator.

14 C.F.R. §91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151(a) prohibits an individual from begi nning “a flight in an airplane under VFR conditions unless (considering wind and f orecast weather conditions) there is enough fuel to fly to the first point of i ntended landing, and, assuming normal cruising speed – (1) During the day, to fly after that for at least 30 minutes.

The battery powering the Coptergraphics PR UAS’s pr ovides approximately 25 minutes of powered flight. To meet the 30-minute r eserve requirement in 14 CFR §91.151, UAS flights will be limited to approximate ly 12-15 minutes in length. Given the limitations on the UAS’s proposed flight area a nd its proposed operations within a predetermined location, a longer time frame for f light in daylight VFR conditions is reasonable. Furthermore, operating the UASs in a t ightly controlled area where only people, property owners, or official representative s who have signed waivers will be allowed, less than 30 minutes of reserve fuel does not engender the type of risk that§91.151(a) was intended to address.

Coptergraphics PR believes that safety can be achie ved by limiting flights to 12-15 minutes or 25% of battery power, whichever occurs f irst. This restriction would be more than adequate to return the UAS to its pre-det ermined landing zone from anywhere in its limited operating area.

Coptergraphics PR is not seeking an exemption for n ighttime UAS operations. 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a ) & (b): Maintenance Inspections.

These regulations require that an aircraft operator or owner shall “have that aircraft inspected as prescribed in subpart E of this part a nd shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter.. .,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Copte rgraphics PR operations. Maintenance will be accomplished by the operator. An equivalent level of safety will be achieved because the UASs are limited in size, w ill carry a small payload and operate only in restricted areas for limited period s of time. If mechanical issues arise, the UAS can land immediately and will be ope rating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to flight, perform any required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the UAS and best suited to maintain it in an airworthy condition.

Privacy

All flights will occur over private or controlled a ccess areas with the property owner’s prior consent and knowledge. Filming will be only of people who have given their consent or otherwise have agreed to be in the area where filming will take place.

Satisfaction of the criteria provided in Section 33 3 of the Reform Act of 2012 (size, weight, speed, operating capabilities, proximity to airports; and populated areas and operation within visual line of sight and national security) provide more than adequate justification to grant Coptergraphics PR r equested exemption, allowing for Coptergraphics PR UAS commercial operations for the aerial photography on real estate industry, agriculture industry, construction industry, motion picture, television industry, surveying and special events.

Summary for Publication

Pursuant to 14 C.F.R. Part 11, the following summar y is provided for publication in the Federal Register, should it be determined that publication is needed:Coptergraphics PR seeks an exemption under Section 333 from the following rules:

14 C.F.R. Part 21, Subpart H; 61.23 (a); 61.113(a) and (b); 91.103; 91.109; 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)( 1); 91.409 (a)(1) and (2); 91.417(a) and (b) to operate commercially a small unmanned aerial veh icle or UAS.

As established by the UAS exemptions already grante d by the FAA, allowing commercial operations will enhance safety by reduci ng risk. Conventional film operations, using turbine aircraft or helicopters, operate at low altitudes and present the risks associated with aircraft that wei gh around 4,000 pounds, and which carry large amounts of Jet A fuel. Such aircr aft must also fly to and from the film location. In contrast, a UAS weighing fewer t han 10 pounds and powered by batteries eliminates virtually all of that risk giv en the small size and lack of combustible fuel. The UAS is carried, and not flow n, to a film set. In this regard, the UAS carries no passengers or crew and, therefore, w ill not expose them to the risks associated with manned flights.

The operation of UASs conducted in the strict condi tions will provide an equivalent level of safety supporting the grant of the exempti on requested herein. The UASs operate at slow speeds, close to the ground, and in a sterile environment. As a result, they are far safer than conventional operat ions conducted with turbine airplanes or helicopters carrying fuel and flying n ear the ground and people.

If you have any questions or need any additional in formation, please contact the undersigned Coptergraphics PR, Attn: Ismael Solá Go tay; Ph: 787-210-2052; Email: coptergraphicspr@gmail.com; Physical Address: Calle Rio Cana, E-5 Hato Nuevo 3 Gurabo, Puerto Rico 00778; Mailing Address: HC 02 B ox 15710, Gurabo, P.R. 00778.

Sincerely yours,

ISMAEL SOLA GOTAY

COPTERGRAPHICS PR