May 16th, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., 

Washington, DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations 

Dear Sir or Madam: 

Pursuant to the Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform 

Act"), Noah Cowles (the "applicant"), operator of an Unmanned Aircraft Systems ("UAS") seeks 

an exemption from the Federal Aviation Regulations ("FARs") to allow for 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 Pilot Training 

Regulations from which the exemption 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) 

Extent of relief I seek, and why: 

14 CFR Part 21 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 

aircraft to be utilized, I request exception. In the restricted environment and under the 

conditions proposed operation will be at least as safe, or safer, than a conventional aircraft 

operating with an airworthiness certificate without said restrictions. 
----------------···-

14 CFR 45.23 (b) 

Due to the size of this UAS it does not have a cockpit, cabin, or pilot station on which to market 

certain words or phrases. Lettering would be very difficult to 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" 

or assigned number or name, based on request/ruling of FAA, on UAS fuselage. The equivalent 

level of safety will be provided by having the UAS marked on its fuselage as required. 

14 CFR 91.7 (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 of the 

aircraft for maintenance and use of safety check list prior to each flight an equivalent level of 

safety will be provided. 

14 CFR 91.9 (b) (2) 

Given the size and configuration, the UAS has no ability to carry a flight manual on the aircraft. 

There is no room, capacity, or pilot on board to adequately carry flight manual. A equivalent 

level of safety will be maintained by keeping the flight manual at ground control point where 

the pilot will have immediate access to it. 

14 CFR 91.103 

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 takeoff distances, along will all of those found in attachment "DJI Pilot 

Training". An equivalent level of safety will be provided by preflight protocol to properly match 

the machine. 

14 CFR 91.109 

UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is 

achieved through the use of a control box that communicates with the aircraft via radio 

communications. The equivalent level of safety provided because neither a pilot nor passenger 

will be carried in the aircraft, and by the speed and size of the aircraft. 

14 CFR 91.113 (a) and (b) 

I can achieve an equivalent level of safety as achieved by current regulations because my UAS 

does not carry pilot nor passenger. While helpful, a pilots' license will not ensure remote control 

piloting skills. 

14 CFR 91.121 

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 of safety 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. 

14 CFR 91.203 (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 on 
board to adequately such documents. An equivalent level of safety wili be achieved by keeping 

these documents, to the extent they are applicable to the UAS, at the ground control point 

where pilot has immediate access to them. 

14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (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 relief from all FARs above preventing applicant from 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 flight time of 25 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 of these 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 

at speeds much less than its top speed of 33.5 mph. Due to the UAS being battery powered 

there are no combustible fuels onboard. Maximum flight time for this 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 aircraft to be utilized I find this 

exception to be reasonable with an equivalent, or greater, level of safety to be reached by the 

operator. 

Safety 

*Please see attachment "DJI Pilot Training" 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 of an airport unless prior contact to Air Traffic Control or 

the airport manager has been made; 

2) I land my UAS prior to manufacturer recommended minimum level of battery power; 

3) I pilot my UAS through remote control by line of sight; 

4) My UAS uses GPS and a flight safety feature whereby it returns to a preprogrammed 

position and then slowly lands if communication with the remote control pilot is lost; 

5) I actively analyze flight data and other sources of information 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 prior to operation; and, 

8) I have procedures in place to abort flights in the event of safety breaches or potential 

danger. 

Public Interest 

The use of an 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 of their home. Quicker home sales also help accelerate the 

economy as a whole. Buyers experience the benefit of encompassing a whole property, 
sometimes several acres, in one photo or a short video. 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 of using a plane or helicopter to achieve the same result. We can now 

provide this level of service while being conservative with fuel, time, emissions, noise, and other 

resources. Considering size, weight, speed, and absence of combustible fuels, my UAS will pose 

much less of a safety concern for the general public when compared to larger manned aircraft.