September 17, 2015

Exemption No. 12916

Regulatory Docket No. FAA

– 20 15

– 2232

Mr. Blake J. Coppinger

8751 West R Avenue

Kalamazoo, MI 49009

Dear Mr. Coppinger :

This letter is to inform you that we have granted your request for exemption. It transmits our

decision, explains its basis, and gives you the conditions and limitations of the exemption,

including the date it ends.

By letter dated May 23, 2015 , you petitioned the Federal Aviation Administration (FAA) for

an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to

conduct aerial photography and videography, including marketing, real estate , landscapes, and

film sets

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and

the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summary of the petition

in the Federal Register because the requested exemption would not set a precedent, and any

delay in acting on this petition would be detrimental to the petitioner

.

Airworthines s Certification

The UAS proposed by the petitioner are the DJI Phantom 3 and DJI Inspire 1

.

In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in

reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited

operating area associated with the aircraft and its operation, the Secretary of Transportation

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA

finds that relief from 14 CFR part 21

, C ert ification procedures for products and parts,2

Subpart H

— Airworthiness Certificates , and any associated noise certification and testing

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1

. The FAA has issued grants of

exemption in circumstances similar in all material respects to those presented in your petition.

In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352),

11109 to Clayco, Inc. ( see Doc ket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No.

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned

aircraft (UA) with the specifications describ ed by the petitioner and carrying no passengers or

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled

by this exemption is i n the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of

Exemption Nos. 11062, 11109, 11112, and 11213 ;

 The reasons stated by the FA A for granting Exemption Nos. 11062, 11109, 11112, and

11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest.

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701,

delegated to me by the Administrator, Mr. Blake Coppinger is granted an ex emption from

14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c),

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection.

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Mr. Blake Coppinger is hereafter referred to as the operator.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA.

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF

analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by

instruments aboard the UA.3

Failure to comply with any of the conditions and limitations of this grant of exemption will be

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3 and

DJI Inspire 1 when we ighing less than 55 pounds including payload. Proposed

operations of any other aircraft will require a new petition or a petition to amend this

exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are not

permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The

exemption holder may use either groundspeed or calibrated airspeed to determine

compliance with the 87 knot speed restriction. In no case will the UA be operated at

airspeeds greater than the maximum UA operating airspeed recommended by the

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times.

This requires the PIC to be able to use human vision unaided by any device other than

corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used

to satisfy the VLOS requirement as long as the PIC always maint ains VLOS

capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC

must be designated before the flight and cannot transfer his or her designation fo r the

duration of the flight. The PIC must ensure that the VO can perform the duties

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its

operations in accordance with the conditions and limitations stated in thi s grant of

exemption, are hereinafter referred to as the operating documents. The operating

documents must be accessible during UAS operations and made available to the

Administrator upon request. If a discrepancy exists between the conditions and

limita tions in this exemption and the procedures outlined in the operating documents,

the conditions and limitations herein take precedence and must be followed.

Otherwise, the operator must follow the procedures as outlined in its operating

documents. The ope rator may update or revise its operating documents. It is the

operator’s responsibility to track such revisions and present updated and revised4

documents to the Administrator or any law enforcement official upon request. The

operator must also present up dated and revised documents if it petitions for extension

or amendment to this grant of exemption. If the operator determines that any update

or revision would affect the basis upon which the FAA granted this exemption, then

the operator must petition for an amendment to its grant of exemption. The FA A’s

UAS Integration Office (AFS− 80) may be contacted if questions arise regarding

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS op eration

or flight characteristics, e.g.

, replacement of a flight critical component, must undergo

a functional test flight prior to conducting further operations under this exemption.

Functional test flights may only be conducted by a PIC with a VO and mu st remain at

least 500 feet from other people. The functional test flight must be conducted in such

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it i s

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the

UAS is in a condition for safe flight. The pre

- flight inspection must account for all

potential discrepancies, e.g.

, inoperable comp onents, items, or equipment. If the

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is

prohibited from operating until the necessary maintenance has been performed and the

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul,

replacement, inspection, and life limit requirements for the aircraft and

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport,

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a

current FAA airman medical certificate or a valid U.S. driver’s license issued by a

state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal

government. The PIC must also meet the flight revi ew requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the

ability to safely operate the UAS in a manner consistent with how the UAS will be

operated under this exemption, including evasive and emergency maneuvers and

main taining appropriate distances from persons, vessels, vehicles and structures. PIC

qualification flight hours and currency must be logged in a manner consistent with5

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs

(trai ni ng, proficiency, and experience

- building) and determining the PIC’s ability to

safely operate the UAS in a manner consistent with how the UAS will be operated

under this exemption are permitted under the terms of this exemption. However,

training operat ions may only be conducted during dedicated training sessions. During

traini ng, proficiency, and experience

- building flights, all persons not essential for

flight operations are considered nonparticipants, and the PIC must operate the UA

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All

operations must be conducted under visual meteorological conditions (VMC). Flights

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not

denoted with an ARP, the center of the airport sy mbo l as denoted on the current

FAA

- published aeronautical chart, unless a letter of agreement with that airport’s

management is obtained or otherwise permitted by a COA issued to the exemption

holder. The letter of agreement with the airport management mus t be made available

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibi ted from beginning a flight unless (considering wind and forecast

weather conditions) there is enough available power for the UA to conduct the

intended operation and to operate after that for at least five minutes or with the reserve

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All

operations shall be cond ucted in accordance with an ATO

- issued COA. The

exemption holder may apply for a new or amended COA if it intends to co nduct

operations that cannot be conducted under the terms of the attached COA

.

22. All aircraft operated in accordance with this exemption must be identified by serial

number, registered in accordance with 14 CFR part 47, and have identification

(N− Number) ma rkings in accordance with 14 CFR part 45, Subpart C. Markings must

be as large as practicable.6

23. Documents used by the operator to ensure the safe operation and flight of the UAS and

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the

PIC at the Ground Control Station of the UAS any time the aircraft is operating.

These documents must be made available to the Administrator or any law enforcement

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and

activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonpartici pating

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons

from the UA and/or debris in the event of an accident. The operator must ensure

that nonparticipating persons r emain under such protection. If a situation arises

where nonparticipating persons leave such protection and are within 500 feet of

the UA, flight operations must cease immediately in a manner ensuring the safety

of nonparticipating persons ; and

b. The owner/ controller of any vessels, vehicles or structures has granted permission

for operating closer to those objects and the PIC has made a safety assessment of

the risk of operating closer to those objects and determined that it does not

present an undue hazard

.

The PIC, VO, operator trainees or essential persons are not considered

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with

permission from the property owner/controller or aut horized representative.

Permission from property owner/controller or authorized representative will be

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the opera tional area as defined by the applicable COA must be reported

to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be

reported to the National Transportation Safety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov

.

If this exemption permits operations for the purpose of closed

- set motion picture and

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a mot ion picture and television operations manual (MPTOM)

as documented in this grant of exemption.7

30. At least 3 days before aerial filming, the operator of the UAS affected by this

exemption must submit a written Plan of Activities to the local Flight Standards

District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day

notification may be waived with the concurrence of the FSDO. The plan of activities

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted

under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of

the UAS;

d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certific ate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners

and/or local officials to conduct the filming production event; the list of those

who gave permission must be made available t o the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city,

town, county, and/or state over which filming will be conducted and the altitudes

essenti al to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons

consenting to be involved and necessary for the filming production, as specified in the

exemption holder’s MPTOM.

Unless otherwise specifie d in this grant of exemption, the UAS, the UAS PIC, and the UAS

operations must comply with all applicable parts of 14 CFR including, but not limited to,

parts 45, 47, 61, and 91.8

This exemption terminates on September 30, 2017 , unless sooner superseded or rescinded.

Sincerely,

/ s/

John S. Duncan

Director, Flight Standards Service

EnclosuresUNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

BLAKE J COPPINGER

FOR AN EXEMPTION SEEKI NG RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE

CODE OF FEDERAL REGULATIONS 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) CONCERNING COMMERCIAL

OPERATION OF DJI PHANTOM 3 AND DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on May 23, 2015

BLAKE J COPPINGER

8751 W R AVE

KALAMAZOO, MI 49009

(269)

- 217

- 3795TAB LE OF CONTENTS

Page

GLOSSARY OF

ABBREVIATIONS.................................................................................................................3

SUMMARY...................................................................................................................... ....... 4

INTRODUCTION AND INTERESTS OF PETITIONER......................................................4

BACKGROUND..................................................................................... ................................5

BASIS FOR PETITION........................................................................................................... 5

NAME AND ADDRESS OF PETITIONER................................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH

BLAKE J COPPINGER SEEKS EXEMPTION..........................................................7

THE EXTENT OF RELIEF BLAKE J COPPINGER SEEKS AND

THE REASON BLAKE J COPPINGER SEEKS THE RELIEF .........................9

THE REASONS WHY GRANTING BLAKE J COPPINGER REQUEST

WOULD BE IN THE PUBLIC INTEREST .............................................................11

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY..............................................................................13

CONCLUSION................................................................................................................... ....19GLOSSARY OF ABBREVIA TIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Comma nd

Section 333 FAA Modernization and Reform Act of 2012 (FMRA)

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

DJI UAV manufacturer

ESC Electronic speed control

FPV First Person View

LI

- PO Lithium Polymer battery

RCV Radio Controlled vehicleSUMMARY

BLAKE J COPPINGER seeks exemption from the requirements of 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), to

operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform

Act of 2012 (FMRA). This exemption will permit BLAKE J COPPINGER to operate an Unmanned

Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography for

Marketing, film sets, r eal estate photography, commercials, special events, wedding cinematography,

and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is Blake J COPPINGER, and I am a drone builder and operator(pilot) with expertise and

knowledge in all aspects of building programing and operating multiple types of UAS'S along with

camera set up and operation. BLAKE J COPPINGER also provides clients with the highest quality

digital content for use in their commercia l, personal, and non

- profit multimedia projects. BLAKE J

COPPINGER has 10 years of RCV experience and 5 years of radio controlled helicopter experience.

BLAKE J COPPINGER is recognized as an expert in this field and has repaired multiple drones for

multiple business.

The objective of Blake J COPPINGER’ aerial video and photography operations is to provide high

quality imaging for a variety of commercial, public, and residential uses, along with test repaired drones

for clients in a safe testing location away form all obstetrical and people at all times. BLAKE J

COPPINGER will also provide knowledge of UAS and promote safe UAS operations.BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3, DJI Inspire 1 UASs

BLAKE J COPPINGER seeks an exemption to operate DJI systems for compensation or hire within the

NAS. The DJI Phantom 3 and DJI Inspire 1 are vertical takeoff and landing (VTOL) Unmanned

Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone s ystems.

The DJI Phantom 3 has a maximum gross weight of approximately 2 pounds 14 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 Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches,

width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJI

Phantom 3 and DJI Inspire 1UAs are equipped with four main rotors; driven by Lithium Polymer

battery power ed electric motors.

The DJI Phantom 3 and DJI Inspire 1 UAs that will be operated by BLAKE J COPPINGER will be

registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47,

Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration

Markings.

BASIS FOR PETITION

Petitioner,BLAKE J COPPINGER, pursuant to the provisions of the Federal Aviation Regulations (14

C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special

Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially

operate the DJI Phantom 3, DJI Inspire 1 UASs in the National Airspace System (NAS), and for an

exemption from the requirements of 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).

In consideration of the speed, weight, size, and limited operating area associated

with the unmanned aircraft and its operation, BLAKE J COPPINGER operation of DJI Phantom 3 and

DJI Inspire 1 UASs 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, BLAKE J COPPINGER requests relief from Sections 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance

that only apply to aircraft with an airworthiness certificate.BLKAE J COPPINGER submits that the requested relief is proper since an equivalent level of safety

will be ensured. BLAKE J COPPINGER will use experienced personnel or technicians to perform

maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and

practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3

and DJI Inspire 1 Instruction Manual). Furthermore, BLAKE J COPPINGER will document and

maintain all maintenance records for the DJI Phantom 3 and DJI Inspire 1 UASs.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and

limitations: Pilot in command, is requested by BLAKE J COPPINGER to the extent necessary to allow

a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman

medical certificate, and who has demonstrated, by meeting minimum flight

- hour and currency

requirements, that the PIC is able to safely operate the DJI Phantom 3 and DJI Inspire 1 UASs in a

mann er consistent with this exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from people, vessels, vehicles and structures.

BLAKE J COPPINGER seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because

the DJI Phantom 3 and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance

with 14 C.F.R. Part 21, Subpart H. As such, BLAKE J COPPINGER submits that he will ensure that

the DJI Phantom 3 and DJI Inspire 1UASs are in an air worthy condition, prior to every flight, by

determining

that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and

DJI Phantom 3 and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe

flight.

BLAKE J COPPINGER also seeks an exemption from the requirements of Section 91.121, entitled

Altimeter Settings, as the DJI Phantom 3 and DJI Inspire 1 UAs will not have a typical barometric

altimeter onboard. However, altitude information of th e DJI Phantom 3 and DJI Inspire 1UAs 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 of the flight path.

This altitude information, combined with BLKAE J COPPINGER’ operation of the DJI Phantom 3and

DJI Inspire 1 UASs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety

equivalent to Section 91.121.

Additionally, BLAKE J COPPINGER seeks an ex emption from the requirements of Section 91.151(b),

entitled Fuel requirements for flight in VFR conditions. BLAKE J COPPINGER submits that safety

will not be affected by operation of the DJI Phantom 3 and DJI Inspire 1 UAs during daylight hours in

visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to

fly for a total duration of approximately 15.5 minutes to the first point of intended landing and,

assuming normal cruising speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, BLAKE J COPPINGER provides the following information in

support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:BLAKE J COPPINGER

8751 W R AVE

Kalamazoo,MI 49009

(269)

- 217

- 3795

Email: Blakecoppinger@hotmail.com

B. The Specific Sections Of 14 C.F.R. From Which BLAKE J COPPINGER Seeks Exemption.

1 BLAKE J COPPINGER Seeks Exemption From The Re quirements Of Section 61.113(a) And

(b).

2 Section 61.113, entitled Private pilot privileges and limitations: Pilot in command,

3

4 subsections (a) and (b) prescribe the following, in relevant part:

5 (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft

that is carrying passengers or property for compensation or hire; nor may that person, for compensation

or hire, act as PIC of an aircraft.

6 (b) A private pilot may, for compensation or hire, act as PIC of an ai rcraft in connection with any

business or employment if

—

7 The flight is only incidental to that business or employment; and

8 (2) The aircraft does not carry passengers or property for compensation or hire.

9

10 2. BLAKE J COPPINGER Seeks Exemption From The Requirements Of Section 91.7(a).

11 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.

12

13 3. BLAKE J COPPINGER Seeks Exemption From The Requirements Of Section 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 or flight

level of that aircraft, as the case may be, by reference to an altimeter that is set,

when operating

--

1 Below 18,000 feet MSL, to

--

2 (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of

the aircraft;

3 (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current

reported altimeter setting of an appropriate available station; or

4 (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an

appropriate altimeter setting available before departure.4. BLAKE J COPPINGER Seeks Exemption From The Requirements Of Section

91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the follo wing:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering

wind and forecast weather conditions) there is enough fuel to fly to the first point of intended

landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

5 BLAKE J COPPINGER Seeks Exemption From The Requirement Of Section 91.405(a).

6

7 Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or

operator of an aircraft

—

8 (a) S hall have that aircraft inspected as prescribed in subpart E of this part and shall between required

inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as

prescribed in part 43 of this chapter[.]

9

6. BLAKE J COPPINGER Seeks Exemption From The Requirements Of Section

91.407(a)(1

6 Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or

alteration, subsection (a)(1), states the following:

7 (a) No person may operate any aircraf t 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 of this chapter[.]

8

9 7. BLAKE J COPPINGER Seeks Exemption From The Requirements Of Sections 91.409(a)(1)

And 91.409(a)(2).

10 Section 91.409, entitled Inspections, subsection (a), states the following:

11 (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless,

within the preceding 12 calendar months, it has had

--

12 (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return

to service by a person authorized by § 43.7 of this chapter; or

13 (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this

chapter.

14

15 8. BLAKE J COPPINGER Seeks Exemption From The Requirements Of Sections 91.417(a)

And 91.417(b).

16 Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following:

17 (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or

operator shall keep the following records for the periods specified in paragraph (b) of this section:

18 Records of the 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 of an aircraft. The records must

include

--

19 (i) A descript ion (or reference to data acceptable to the Administrator) of the work performed; and

20 (ii) The date of completion of the work performed; and21 (iii) The signature, and certificate number of the person approving the aircraft for return to service.

22 Records containing the following information:

23 (i) The total time in service of the airframe, each engine, each propeller, and each rotor.

24 (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance.

25 (iii) The time s ince last overhaul of all items installed on the aircraft which are required to be

overhauled on a specified time basis.

26 (iv) The current inspection status of the aircraft, including the time since the last inspection required

by the inspection program under which the aircraft and its appliances are maintained.

27 (v) The current status of applicable airworthiness directives (AD) and safety directives including, for

each, the method of compliance, the AD or safety directive number and revision date. If the AD or

safety directive involves recurring action, the time and date when the next action is required.

28 (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the

airframe and currently installed engines, rotors, propellers, and appliances.

29

30 (b) The owner or operator shall retain the following records for the periods prescribed:

31 (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is

repeated or superseded by other work or for 1 year after the work is performed.

32 (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the

aircraft at the time the aircraft is sold.

33 (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be

retained until the defects are repaired and the aircraft is approved for return to service.

34

35 C. The Extent Of Relief BLAKE J COPPINGER Seeks And The Reason BLAKE J

COPPINGER Seeks The Relief.

36 1. Extent Of Relie f BLAKE J COPPINGER Seeks And The Reason BLAKE J COPPINGER

Seeks Relief From Section 61.113(a) And (b).

37 Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in

command, is requested to the extent necessary to allow a PIC holding

a private pilot or higher level certificate, as well as a current and valid airman medical

certificate, and who has met certain flight

- hour and currency requirements, to conduct the

proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state

that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with

any business or employment if: (1) The flight is only incidental to that business or employment;

and (2) The aircraft does not carry passengers or property for compensation or hire.

As set forth more fully below, BLAKE J COPPINGER submits that an equivalent level

of safety will be maint ained because no PIC will be allowed to operate the DJI Phantom 3 UAS

or DJI Inspire 1 UAS unless that PIC has met certain flight

- hour and currency requirements,

demonstrating that the PIC is able to safely operate either the DJI Phantom 3 or DJI Inspire 1

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, BLAKE J C OPPINGER submits that all flights of the DJI Phantom 3 and DJI

Inspire 1 UASs, conducted by the PIC pursuant to the grant of this Petition: (1) will be

incidental to BLAKE J COPPINGER' business; and (2) will not carry passengers or property for

compensation or hire.2 Extent Of Relief BLAKE J COPPINGER Seeks And The Reason BLAKE J COPPINGER Seeks

Relief From Section 91.7(a).

3

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the

extent required to allow BLAKE J COPPIN GER to determine that the DJI Phantom 3 and DJI

Inspire 1 UASs are in airworthy condition prior to every flight by ensuring that the UAS is in

compliance with the operating documents (i.e., BLAKE J COPPINGER Aerial Operations

Manual, Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 Instruction Manual).

BLAKE J COPPINGER seeks the requested relief because the DJI Phantom 3 and DJI

Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21,

Subpart H. T herefore, BLAKE J COPPINGER will ensure that the DJI Phantom 3 and DJI

Inspire 1 UASs are in airworthy condition based upon its compliance with the operating

documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 Instruction

Manual) prior to every flight, and further, determine that the aircraft are in condition for safe

flight, as stated in the conditions and limitations below.

3. Extent Of Relief BLAKE J COPPINGER Seeks And The Reason BLAKE J

COPPINGER Seeks Relief From Sec tion 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight

operations of the DJI Phantom 3 and DJI Inspire 1 UASs, which utilize a barometric pressure

sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude

information from the UA to the PIC at the ground control station (GCS). Since the FAA requires

that any altitude information concerning UAS operations be reported to air traffic control (ATC)

in feet above ground leve l (AGL), BLAKE J COPPINGER seeks the requested relief because

the DJI Phantom 3 and DJI Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL,

rather than the local barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121

is sought to the extent necessary to comply with the applicable conditions and limitations stated

below. As more fully set forth herein, an equivalent level of safety will be maint ained since the

DJI Phantom 3 and DJI Inspire 1 UAs are equipped with a barometric pressure sensor and GPS

equipment, which automatically ensures that a ground level pressure setting will be established

prior to each flight, and provides the PIC with altitude information of the UA on the heads

- up d

isplay of the GCS.

4. Extent Of Relief BLAKE J COPPINGER Seeks And The Reason BLAKE J

COPPINGER Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is

requested to the extent required to allow flights of the battery powered DJI Phantom 3 and DJI

Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual

flight rules (VFR), for a total duration of 15.5 minutes to the first point of intended landing and,

assuming normal cruising speed, to fly after that for at least 4.5 minutes. BLAKE J

COPPINGER seeks the requested relief because without an exemption from Section 91.151(b),

the flight time durat ion of the battery powered DJI Phantom 3 and DJI Inspire 1 UAs will

severely constrain the practicality of any aerial video or still photo flight operations that

BLAKE J COPPINGER proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom 3 and

DJI Inspire 1 UASs, the DJI Phantom 3 and DJI Inspire 1 operating documents, and BLAKE J

COPPINGER proposed operating limitations, ensure that BLAKE J COPPINGER will safelyoperate the bat tery powered DJI Phantom 3 and DJI Inspire 1 UAs during daylight hours in

visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery

power to fly for a total duration of 13.5 minutes to the first point of intended landing and,

assuming normal cruising speed, to fly after that for at least 4.5 minutes.

5 5.Extent Of Relief BLAKE J COPPINGER Seeks And The Reason BLAKE J COPPINGER

Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b)

.

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only

apply to aircraft with an airworthiness certificate, BLAKE J COPPINGER requests relief from

these Sections because the DJI Phantom 3 and DJI Inspire 1 UASs do not require airworthiness

certificates. As set forth more fully below, the DJI Phantom 3 and DJI Inspire 1 UASs meet the

conditions of FMRA Section 333 for operation without an airworthiness certificate.

Accordingly, BLAKE J COPPINER will use trained tec hnicians to perform maintenance,

alterations, or preventive maintenance on the UASs using the methods, techniques, and

practices prescribed in the UAS operating documents (i.e., BLAKE J COPPINGER Aerial

Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1

Instruction Manual). Furthermore, BLAKE J COPPINGER will document and maintain all

maintenance records for the DJI Phantom 3 and DJI Inspire 1 UASs.

D The Reasons Why Granting BLAKE J COPPINGER Request Would Be In The Publ ic Interest;

That Is, How It Would Benefit The Public As A Whole.

DI

Granting the present Petition will further the public interest by allowing BLAKE J

COPPINGER to safely, efficiently, and economically perform aerial video and photography of

construction sites, real estate, and landscape over certain areas of the United States.

Additionally, use of the DJI Phantom 3 and DJI Inspire 1 UASs will decrease congestion

of the NAS, reduce pollution, crashes and accidents caused by pilot error and provide

significant benefits to the economy. Notably, the benefits of BLAKE J COPPINGER’ proposed

operation of the DJI Phantom 3 and DJI Inspire 1 UASs will be realized without implicating

any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Phantom 3 and DJI Inspire 1 UAs are battery powered and serve as a safe,

efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial

imagery. By reducing the amount of manned aircraft ne eded to perform aerial acquisitions, an

exemption allowing the use of a DJI Phantom 3 or DJI Inspire 1 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 3 and DJI Inspire 1 UAs do not require an airpo rt to takeoff or land. Likewise, a

reduction of manned aircraft conducting aerial video and photography missions would result in

fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure,

arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3

and DJI Inspire 1 UASs.Conducting aerial acquisitions with the DJI Phantom 3 and DJI Inspire 1 UASs, instead

of manned aircraft, will greatl y benefit the public by drastically reducing the levels of air and

noise pollution generated during traditional aerial video and still photography flight operations.

By using battery power and electric motors, the DJI Phantom 3 and DJI Inspire 1 UASs produce

no air pollution, and is the most viable environmentally conscious alternative to the cabin class,

six cylinder internal combustion engine aircraft that are typically utilized for aerial video and

photography, while burning approximately 20

- 30 gall ons per hour of leaded aviation fuel. The

DJI Phantom 3 and DJI Inspire 1 UAs, while reducing the carbon footprint of aerial

acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered

electric motors, rather than an internal combustion engine.

By using the DJI Phantom 3 and DJI Inspire 1 UASs to perform aerial acquisitions, the

substantial risk to life and property in the air and on the ground, which is usually associated

with traditional manned aircraft flight opera tions, will be substantially reduced or completely

eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI

Phantom 3 and DJI Inspire 1 UAs (weighing approximately 2 pounds 14 ounces and 6 pounds

7.5 ounces respectively, at their maximum gross weights with lengths of 16 inches and 17.3

inches respectively, widths of 16 inches and 17.7 inches respectively, and with no fuel on

board), has less physical potential for collateral damage to life and property on the ground, and

in the air, compared to the manned aircraft that typically conduct similar operations (weighing

approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and

a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI Phantom

3 and DJI Inspire 1 UASs Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3 and DJI Inspire 1 UASs are

also an economical alternative to using manned aircra ft to conduct similar aerial operations. As

such, operation of the DJI Phantom 3 and DJI Inspire 1 UASs will allow United States based

companies, like Kalamazoodrones, to remain competitive and contribute to growth of the U.S.

economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection

Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated

companies must adopt new and alternative technology in order to remain competitive.

Operatin g the battery powered DJI Phantom 3 and DJI Inspire 1 UASs is one such technology

that not only allows companies greater operational flexibility compared to manned aircraft, but

provides such flexibility without the high operational cost of a traditional manned aircraft.

By operating the DJI Phantom 3 and DJI Inspire 1 UASs, companies such as

Kalamazoodrones, can remain competitive and profitable, and therefore, provide greater job

stability to employees and contractors, which will ultimately contri bute to growth of the U.S.

economy. Improved financial performance of U.S. companies, through commercial use of the

DJI Phantom 3 and DJI Inspire 1 UASs, provides a stable workforce that increases consumer

spending; improves local, state, and federal tax revenues; and allows companies to invest in

research and development in order to remain competitive both in the United States and abroad.

4 There Are No Privacy Issues.

5

Similar to the manned aerial acquisition flight operations that have been conduct ed for

decades, BLAKE J COPPIGNER proposed operation of the DJI Phantom 3 and DJI Inspire 1

UASs will not implicate any privacy issues. Specifically, the DJI Phantom 3 and DJI Inspire 1UASs will be operated only in compliance with operating documents (i.e., BLAKE J

COPPINGER Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 and

DJI Inspire 1 Instruction Manual) which requires property owner involvement as well as local

law enforcement notification, and in accordance with the Federa l Aviation Regulations,

including the minimum altitude requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or

How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided

By The Rule From Which BLAKE J COPPINGER Seeks Exemption.

1 Reasons Why The DJI Phantom 3 and DJI Inspire 1 UAs Meet The Conditions Of The FAA

Modernization and Reform Act of 2012 (FMRA) Section 333.

2

In consideration of the size, weight, sp eed, and limited operating area associated with

the unmanned aircraft and its operation, BLAKE J COPPINGER’ operation of the DJI Phantom

3 and DJI Inspire 1 UASs meet the 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

authority for a UAS to operate without airworthiness certification and sets forth requirements

for considering whether a UAS will create a hazard to users of the NAS or the public, or

otherwise pose a threat to national security. Specifically, FMRA Section 333 states the

following, in part:

(a) In General.

-- Notwithstanding any other requirement of this subtitle, and not later

than 180 days after the date of enactment of this Act, the Secretary of Transportation shall

determine if certain unmanned aircraft systems may operate safely in the national airspace

system before completion of the plan and rulemaking required by section 332 of this Act or the

guidance required by sectio n 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.

-- In making the determination under

subsection (a), the Secretary shall determine, at a minimum

-- (1) which types of unmanned aircraft systems, if any, as a result of their size,

weight, speed, operational capability, proximity to airports and populated areas, and operation

within visual line of sight do not create a hazard to users of the national airspace system or the

public or pose a threat to national security; and whether a ce rtificate of waiver, certificate of

authorization, or airworthiness certification under section 44704 of title 49, United States Code,

is required for the operation of unmanned aircraft systems identified under paragraph (1).

(c) Requirements for Safe Operation.

-- If the Secretary determines under this section that

certain unmanned aircraft systems may operate safely in the national airspace system, the

Secretary shall establish requirements for the safe operation of such aircraft systems in the

nat ional airspace system.

In seeking this exemption, BLAKE J COPPINGER submits that the DJI Phantom 3 and

DJI Inspire 1 UASs can operate safely in the NAS pursuant to FMRA Section 333, as

demonstrated by: (a) the characteristics of the DJI Phantom 3 and DJI Inspire 1 UASs; (b) thepilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 3 and DJI Inspire 1 UASs Demonstrate

Its Safe Characteristics.

The DJI Phantom 3 and DJI Inspire 1 UASs do not create a hazard to users of the NAS or the

public, or otherwise pose a threat to national security considering its size, weight, speed, and

operational capability.

i. Technical Specifications Of The DJI Phantom 3 and DJI Inspire 1 UASs.

The technical specifications of the DJI Phantom 3 and DJI Inspire 1 UASs are set forth by the

DJI Phantom 3 and DJI Inspire 1 Specifications and Data Sheet, attached hereto as Exhibit A

and B.

ii. The DJI Phantom 3 and DJI Inspire 1 UASs Autono mous Flight And Navigation

Modes Enable The UASs To Remain Within A Defined Operational Area.

The DJI Phantom 3 and DJI Inspire 1 UASs may be operated in both manual and fully

autonomous flight modes. A complete description of the flight and navigational modes of the

DJI Phantom 3 and DJI Inspire 1 UASs is provided at pages 25

- 35 of the DJI Phantom 3 and

pages 12

- 16 and 45

- 50 of the DJI Inspire

1 User Manuals, attached hereto as Exhibit C and D.

iii. The DJI Phantom 3 and DJI Inspire 1 UASs A re Designed For Automatic

Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or

Navigation.

When the Control Link is lost, the DJI Phantom 3 and DJI Inspire 1 UAs will remain stationary,

in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 and DJI Inspire 1 UAs do

not reacquire control link data from the GCS, the UAs will assume that the Control Link is lost

and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to

t he takeoff position and shutdown.

A complete description of the Failsafe Functions of the DJI Phantom 3 UAS are set

forth at pages 27 through 29 and for the DJI Inspire 1 at pages 13 through 15 of the DJI

Phantom 3 and DJI Inspire 1 User Manuals, attached hereto as Exhibit C and D.

iv The DJI Phantom 3 and DJI Inspire 1 GCS And Its Operation.

A complete description of the operation and specifications of the DJI Phantom 3 and

DJI Inspire 1 GCS and flight control software is provided at pages 32 thro ugh 43 of the DJI

Phantom 3 User Manual and pages 40 through 47 of the DJI Inspire 1 User Manual. DJI

Phantom 3 and DJI Inspire 1 User Manuals are attached hereto as Exhibits C and D.

b. Flight Operations Of DJI Phantom 3 and DJI Inspire 1 UASs Are Limited To

The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

BLAKE J COPPINGER will only utilize certificated pilots who possess a current and valid

airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 3 and DJI

Inspire 1 UASs. Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of DJI Phantom 3 and DJI Inspire 1 UASs Will Be Conducted Pursuant

To Specific Operating Limitations.

In seeking this exemption, BLAKE J COPPINGER proposes to commercially operate DJI

Phantom 3 and DJI Inspire 1 UASs for the special purpose of conducting aerial video and

photography over certain areas of United States, pursuant to the following specific operating

limitatio ns:

1. Operations authorized by this grant of exemption will be limited to the following

aircraft described in the operating documents, rotorcraft UASs weighing less than 55 poundsmaximum gross weight: DJI Phantom 3 and DJI Inspire 1 Unmanned Aircraft Systems.

Proposed operations of any other aircraft will require a new petition or a petition to amend this

grant.

2. UAS operations under this exemption will be limited to conducting operations for the

purpose of aerial video and photography.

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground level

(AGL), as indicated by the procedures specified in the operating documents unless a special

request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times.

This requires the PIC to be able to use human vision unaided by any device other than

corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not

permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the

VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must

be able to communicate verbally at all times. Electronic messaging or texting is not permitted

during flight operations. The PIC m ust be designated before the flight and cannot transfer his or

her designation for the duration of the flight. The PIC must ensure that the SO can perform the

functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and

avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to

operate the camera or other instruments.

9. The operating documents and the grant of exemption must be acces sible during UAS

operations and made available to the Administrator upon request. If a discrepancy exists

between the conditions and limitations contained in the grant of exemption and the procedures

outlined in the operating documents, the conditions and limitations contained in the grant of

exemption take precedence and must be followed. Otherwise, the operator must follow the

procedures as outlined in its operating documents. The operator may update or revise its

operating documents. It is the oper ator’s responsibility to track such revisions and present

updated and revised documents to the Administrator upon request.

The operator must also present updated and revised documents if it petitions for extension or

amendment to the grant of exemption. If the operator determines that any update or revision

would affect the basis upon which the FAA granted the exemption, then the operator must

petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80)

may be contacted if questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition f

or safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the

aircraft is prohibited from operating until the necessary maintenance has been performed and

the UAS is found to be in a condition for safe flight. The Ground Control Station must be

included in the preflight inspection. All mainten ance and alterations must be properly

documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS

operation or flight characteristics, e.g. replacement of a flight critical component, must undergo

a functional test flight. The PIC who conducts the functional test flight must make an entry in

the aircraft records.

12. The pre

- flight inspection must account for all potential discrepancies, e.g.inoperable components, items, or equipment, not already covered in the relevant sections of the

operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component,

maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. Maintenance, inspection, alterations,

and status of replacement/overhaul component parts must be noted in the aircraft records,

including total time in service, description of work accomplished, and the signature of the

authorized person returning the UAS to service.

15. Each UASs operated under this exemption must comply with all manufacturer

Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective

action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a cu rrent third

class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s

qualification criteria and demonstrates the ability to safely operate the UAS in a manner

consistent with how the UAS will be operated under the exemption, including evasive and

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles

and structures. PIC qualification flight hours must be logged in a manner consistent with 14

C.F.R. § 61. 51(b). Flights for the purposes of training the operator’s PICs are permitted under

the terms of the exemption. However, training operations may only be conducted during

dedicated training sessions. During training, proficiency, and experience

- building flights, all

persons not essential for flight

operations are considered nonparticipants, and the PIC must operate the UA with appropriate

distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted d uring night, as defined in 14 C.F.R. § 1.1.

All operations must be conducted under visual meteorological conditions (VMC). If flight at

night is required, a special request will be made at the FAA office closest to proposed area of

operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as

denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that

airport’s ma nagement is obtained, and the operation is conducted in accordance with a NOTAM

as required by the operator’s COA. The letter of agreement with the airport management must

be made available to the Administrator upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a pre

determined location wi thin the planned operating area and land or be recovered in accordance

with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast

weather conditions) there is enough power to fly at normal cruising speed to the intended

landing point and land the UA with 25% battery power remaining.

25. The operator must o btain an Air Traffic Organization (ATO) issued Certificate of

Waiver or Authorization (COA) prior to conducting any operations under the grant ofexemption. This COA will also require the operator to request a Notice to Airman (NOTAM)

not more than 72 hours in advance, but not less than 48 hours prior to the operation. All

operations shall be conducted in accordance with airspace requirements in the ATO issued COA

including class of airspace, altitude level and potential transponder requirements.

2 6. All aircraft operated in accordance with the exemption must be identified by serial

number, registered in accordance with 14 C.F.R. part 47, and have identification (N

- Number)

markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as

practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and

control of the UA must comply with the Federal Communications Commission (FCC) or other

appropriate government oversight agency requireme nts.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to

the PIC at the Ground Control Station of the UAS any time the

UAS is operating. These documents must be made available to the Administrator or any law

enforcement official upon request.

29. The UA must remain clear and yield the right of way to all manned aviation

operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle. 31.

Flight operat ions must be conducted at least 500 feet from all nonparticipating persons (persons

other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures

unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons

from the UA and/or debris in the event of an accident. The operator must ensure that

nonparticipating persons remain under such protection. If a situation arises where

nonparticipating persons leave such protection and are within 500 feet of the UA, flight

operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the

owner/controller of such vessels, vehicles or structures has granted permission and the PIC has

made a safety assessment of the risk of operating closer to those objects and determined that it

does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not

present an undue hazard to tho se persons per § 91.119(a).

32. All operations shall be conducted over private or controlled

- access property with

permission from the land owner/controller or authorized representative. Permission from land

owner/controller or authorized representative will be obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA must be reported to the

FAA's UAS Int egration Office (AFS

- 80) within 24 hours. Accidents must be reported to the

National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site:

www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And

(b) Would Not Adversely Affect Safety.

BLAKE J COPPINGER submits that the equivalent level of safety established by Section

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI

Phantom 3 and DJI Inspire 1 UASs unless that PIC has demonstrated, by meeting minimum

flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and

emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures.

Considering BLAKE J COPPINGER’ proposed area of operations, and the operating

limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge

requirements to those of commercial pilot requirements (See Exemption No. 11062); and the

airmanship skills necessary to safely operate the DJI Phantom 3 or DJI Inspire 1 UAS, BLAKE

J COPPINGER submits that the additional manned airmanship experience of a commercially

certificated pilot would not correlate to the airmanship skills necessary for BLAKE J

COPPINGER’ specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS,

in circumstances similar, in all material respects, to those 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). BLAKE J COPPINGER will not allow any PIC to

operate the DJI Phantom 3 or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting

minimum flight

- hour requirements or the DJI Phantom 3 or DJI Inspire 1 UAS training and

currency requirements, that the PIC is able to safe ly operate the DJI Phantom 3 or DJI Inspire 1

UAS in a manner consistent with this exemption, including evasive and emergency maneuvers

and maintaining appropriate distances from people, vessels, vehicles and structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R.

§ 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those

hours as a UAS pilot operating the same make and model of UAS to be used for operations

under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs

and landings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight

experience that was obtained in compliance with applicable regulations will ensure an

equivalent level of safety during BLAKE J COPPINGER’ proposed operations. The

Administrator has held that prior documented flight experience that was obtained in compliance

with applicable regu lations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of

motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner

consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10

hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062,

the PIC must also have accumulated and logged a min imum of 5 hours as a UAS pilot operating the

same make and model of UAS to be used for operations under the exemption. For clarification, the

FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make

and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included

in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must

accomplish 3 takeoffs and landings in the preceding 90 days (for curren cy purposes). The FAA finds

that at a minimum, the flighthour requirements in Exemption No. 11062 are appropriate to practice and

build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA

also finds that prior documented flight experience that was obtained in compliance with applicable

regulations would satisfy this requirement. Training, proficiency, and experience

- building flights can

also be conducted under the grant of exemption to accomplish the required flight time. During training,

proficiency, and experience

- building flights the PIC is required to operate the UA with appropriate

distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.Accordingly, BLAKE J COPPINGER will ensure safe operations by not allowing any PIC to

operate the DJI Phantom 3 or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting

minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI

Phantom 3 or DJI Insp ire 1 UAS in a manner consistent with the exemption, including evasive

and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles

and structures.

CONCLUSION

BLAKE J COPPINGER seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section

333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe

operation of the DJI Phantom 3 and DJI Inspire 1 UASs commercially, without an airworthiness

certificate, for t he limited purpose of conducting aerial video and photography over certain

areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the

Congressional mandate of the FAA Modernization and Reform Act of 2012, while also

advancing the interests of the public, by allowing BLAKE J COPPINGER to safely, efficiently,

and economically operate the DJI Phantom 3 and DJI Inspire 1 UASs commercially within the

NAS. WHEREFORE, in accordance with the Federal Aviation Regulation s and the FAA

Modernization and Reform Act of 2012, Section 333, BLAKE J COPPINGER respectfully

requests that the Administrator grant this Petition for an exemption from the requirements of 14

C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)

(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI Phantom 3 and

DJI Inspire 1 UASs commercially for the purpose of conducting aerial video and photography

over certain areas of the United Sta tes. Dated: May 22, 2015

Submitted by

BLAKE J COPPINGER

APPENDIX

– A

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS

BLAKE J COPPINGER only utilizes safe and reliable UASs. DJI is an industry leader in small UASproduction. DJI UASs are loaded with ground breaking software enabling the user to set parameters

which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no

higher than a predetermined a nd set altitude as well as limit flight to a predetermined and set distance.

In addition, DJI software provides real

- time altitude and location information to the PIC via the linked

monitor (smart phone/tablet devices)

1.1 DJI Phantom 3

1.2 1.1.1 Aircraft

1.1.1.1 Supported Battery

– DJI 6000AH LiPo Battery

1.1.1.2 Weight (Battery & Propellers Included)

– 2lbs 11.810oz (1242g)

1.1.1.3 Hover Accuracy (Ready to Fly)

– Vertical: .8m; Horizontal: 2.5m

1.1.1.4 Max Yaw Angular Velocity

- 200/s

1.1. 1.5 Max Tilt Angel

- 35 1.1.1.6 Max Ascent Speed

– 6m/s

1.1.1.7 Max Descent Speed

– 2m/s

1.1.1.8 Max Flight Speed

– 15m/s (NOT RECOMMENDED)

1.1.2 Gimbal

1.1.2.1 Working Current

– Static: 750mA; Dynamic: 900mA

1.1.2.2 Control Accuracy

- ±0.03

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 Operating Temperature Range

- 32F

- 104F (0C

- 40C)

1.1.3.2 Sensor Size

– 1/2.3”

1.1.3.3 Effective Pixels

– 14M

1.1.3.4 Resolu tion

– 4384x3288

4.1.3.5 HD Video Recording

– 1080p30 & 720p

4.1.3.6 Recording Field of View

- 110/85

APPENDIX

– B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

BLAKE J COPPINGER only utilizes safe and reliable UASs. DJI is an industry leader in small UAS

production. DJI UASs are loaded with ground breaking software enabling the user to set parameters

which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no

higher than a predetermined and set altitude as we ll as limit flight to a predetermined and set distance.

In addition, DJI software provides real

- time altitude and location information to the PIC via the linked

monitor (smart phone/tablet devices)

All specifications can be found in the attached user manual or at

http://www.dji.com/product/inspire

- 1/spec