May 16th, 2015

U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., Washington, DC 20590

RE: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations

Dear Sir or Madam:

Pursuanttothe Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act"), Noah Cowles (the "applicant"), operator ofan Unmanned Aircraft Systems ("UAS") seeks

an exemption from the Federal Aviation Regulations ("FARs") to allowfor commercial operation for aerial imaging and video of homes and properties for sale in Florida.


### Applicant Noah Cowles 4150 San Ysidro Way Rockledge, FL 32955



### Attachment DJI PilotTraining


### Regulationsfrom which theexemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 (c) 14 CFR 91.121 14 CFR 91.203 (a) and (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) and (b)



### ExtentofreliefI seek, and why:

14CFR Part21 subpart H The UAS to be operated carries neither pilot nor passenger and carries no explosive materials or flammable liquids. Given the size, weight, speed, and limited operating area associated with the aircraftto be utilized, I request exception. In the restricted environment and underthe conditions proposed operation will be at least as safe, orsafer, than a conventional aircraft operating with an airworthiness certificate without said restrictions.----------------···-



### 14CFR45.23(b) Due to the size ofthis UAS itdoes not have a cockpit, cabin, or pilot station on which to market certain words or phrases. Lettering would be very difficultto place on such a small aircraft and dimensions would need to be smaller than required minimum. Understanding the importance of lettering I will mark my UAS with the largest possible letters by placing the word "Experimental"
orassigned number or name, based on request/ruling of FAA, on UAS fuselage. The equivalent level ofsafety will be provided by having the UAS marked on its fuselage as required.



### 14CFR91.7 

### (a) As there will be no airworthiness certificate for the aircraft, should this exemption be granted,
no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraftfor maintenance and use ofsafety check list priorto each flight an equivalent level of safety will be provided.



### 14CFR91.9 (b) (2) Given the size and configuration, the UAS has no abilityto carry a flight manual on the aircraft. There is no room, capacity, or pilot on board to adequately carry flight manual. A equivalent level ofsafety will be maintained by keeping the flight manual atground control pointwhere the pilotwill have immediate access to it.



### 14CFR91.103 As FAA approved flight manuals will not be provided for the aircraft an exemption will be needed. Normal procedures including but not limited to; reviewing weather, flight battery requirement, landing and takeoffdistances, along will all ofthose found in attachment "DJI Pilot Training". An equivalent level ofsafety will be provided by preflight protocol to properly match the machine.



### 14CFR91.109 UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved through the use ofa control box that communicates with the aircraftvia radio communications. The equivalent level ofsafety provided because neither a pilot nor passenger will be carried in the aircraft, and by the speed and size ofthe aircraft.



### 14CFR91.113 (a)and (b) I can achieve an equivalent level ofsafety as achieved by current regulations because my UAS does notcarry pilot nor passenger. While helpful, a pilots' license will notensure remote control piloting skills.



### 14CFR91.121 The UAS may not have a barometric altimeter, but instead does have a GPS altitude read out. I believe an exemption may be needed. An equivalent level ofsafety is achieve by the operator receiving live flight data monitoring and confirming current altitude along with altitude of launch site shown on GPS altitude indicator.



### 14CFR91.203 (a)and (b) Similar to, 14 CFR 91.9 (b) (2), given the size and configuration, the UAS has no ability to carry certificate and registration documents on the aircraft. There is no room, capacity, or pilot onboard to adequately such documents. An equivalent level ofsafety wili be achieved by keeping these documents, to the extentthey are applicable to the UAS, atthe ground control point where pilot has immediate access to them.



### 14CFR91.405(a), 14CFR91.407(a) (1), 14CFR91.409(a) (2), 14CFR91.417(a) and (b) Given these section only apply to aircraft with an airworthiness certificate, theses sections do not apply to this applicant. As a safety precaution, operator will perform preflight inspections and ensure UAS is in working condition before initiating each flight.

Noah Cowles is seeking relieffrom all FARs above preventing applicantfrom conducting aerial photography and video of real estate taken at levels less than 400ft, at a speed less than 33.5 mph, and with a maximum flighttime of25 minutes,. The drone to be used is a DJI Phantom 2 Plus or DJI Inspire 1. At 2.8 pounds (DJI Phantom 2 Plus) and 6.5 pounds (DJI Inspire 1), the weight ofthese UAS meets the definition of "small unmanned aircraft" found in section 331.

''The Reform Act". In order to obtain high quality photography and video the UAS will be used atspeeds much less than its top speed of33.5 mph. Due to the UAS being battery powered there are no combustible fuels onboard. Maximum flighttime forthis particular UAS is 25 minutes battery life, flights to be terminated with 25% battery life remaining. Given the size, weight, speed, and limited operating area associated with the aircraftto be utilized I find this exception to be reasonable with an equivalent, or greater, level ofsafety to be reached bythe operator. 

### Safety *Please see attachment "DJI PilotTraining" for safety precautions I use for every flight. Aside from these practices I was given a hands on training course when I purchased my UAS.

Additionally: 1) I do not operate within 5 miles ofan airport unless priorcontact to AirTraffic Control or the airport manager has been made; 2) I land my UAS priorto manufacturer recommended minimum level of battery power; 3) I pilot my UAS through remote control by line ofsight; 4) My UAS uses GPS and a flight safety feature whereby it returns to a preprogrammed position and then slowly lands ifcommunication with the remote control pilot is lost; 5) I actively analyze flight data and othersources ofinformation to constantly update and enhance safety protocols; 6) I conduct extensive pre-flight inspections and protocol, during which safety carries primary importance; 7) I always obtain all necessary permissions priorto operation; and, 8) I have procedures in place to abortflights in the event ofsafety breaches or potential danger.



### Public Interest The use ofan UAS in the real estate industry provides both buyers and sellers a higher level of service. For a buyer a higher level of marketing and advertising is achieved, appealing to more buyers, resulting in a quicker sale oftheir home. Quicker home sales also help accelerate the economy as a whole. Buyers experience the benefit ofencompassing a whole property,

### sometimes several acres, in one photo or ashortvideo. Not only does this benefit the specific home seller or home buyer, but it benefits the general public because it is much more efficient than traditional ways ofusing a plane or helicopterto achieve the same result. We can now provide this level ofservice while being conservative with fuel, time, emissions, noise, and other
resources. Considering size, weight, speed, and absence ofcombustible fuels, my UAS will pose much less ofasafety concern for the general public when compared to larger manned aircraft.