Miles Cooksy 6/9/15

EPIC Creative

3014 E Progress Drive

West Bend, WI 53142

U.S. Department of Transportation

Docket Management System 1200

New Jersey Ave., SE Washington DC 20590 

Dear Sir or Madam: 

In accordance with Section 333 of the FAA Modernization and Reform Act of 

2012 (the Reform Act) and 14 CFR Part 11, EPIC Creative/Miles Cooksy hereby 

applies for an exemption from the listed Federal Aviation Regulations (FARs) to 

allow commercial use of its Small Unmanned Aircraft Systems (SUASs), so long 

as such operations are conducted within and under the conditions outlined herein 

or as may be established by the FAA as required by Section 333. 

Miles Cooksy/EPIC Creative is requesting this exemption because - (1) existing 

regulations will severely hinder and burden EPIC Creative/Miles Cooksy (2) EPIC 

Creative/Miles Cooksy can provide and execute a level of PIC competence and 

safety that is, at the very least, equal to (or greater than in many cases) to those 

provided by existing guidelines, and (3) the request is in the public interest and 

local benefit. 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 Unmanned Aircraft Systems, provide an opportunity to authorize 

certain SUAS operations in the National Airspace System (NAS) prior to 

implementation of the SUAS rule. This incremental step will allow Miles 

Cooksy/Epic Creative to safely and legally enter into the NAS. 

The requested exemption will permit EPIC Creative/Miles Cooksy to operate its 

SUAS under closely monitored conditions in airspace that is confined/limited 

(<300 meters in any direction and <100 meters altitude), predetermined and 

agreed upon, controlled to access and would provide safety enhancements to the 

already safe operations of those aircraft of similar size, weight, speed, and 

operating capability that have been granted entry into the NAS via the rules in 

Academy of Model Aeronautics (AMA) National Aircraft Safety Code. Approval of 

this exemption would thereby greatly enhance safety and fulfill the Secretary of 

Transportation’s (the Secretary) responsibilities to “... establish requirements for 

the safe operation of such aircraft systems in the national airspace system” per 

Section 333 (c) of the Reform Act. 

Miles Cooksy/Epic Creative is requesting exemption from the following 

regulations: 

14 CFR Part 21, Subpart H; 14 CFR 61.113 (a) and (b); 14 CFR 91.109; 14 CFR 

91.121; 14 CFR 91.151; (a); 14 CFR 91.405 (a); 14 CFR 91.407 (a)(1); 14 CFR 
91.409 (a)(1); 14 CFR 91.409 (a)(2); 14 CFR 91.417 (a) and (b) to commercially 

operate small unmanned aircraft systems (55 lbs. or less) in order to safely and 

legally capture aerial photography and videography for use by golf courses, 

residences, business to business marketing, and farming.		Application is 

expressly submitted to fulfill Congress’ goal in passing through (c) of the Reform 

Act. This law directs the Secretary to consider that unmanned aircraft systems 

may operate safely in the NAS.

This exemption Section 333 (a)whether certain completion of the rule-making 

required under Section 332 of the Reform Act. In making this determination, the 

Secretary is required to determine which types of UASs do not create a hazard to 

users of the NAS, to the public, or pose a threat to national security. 

Section 333 of the Reform Act grants the Secretary authority to determine (1) if 

an unmanned aircraft system, as a result of its size, weight, speed, operational 

capability, proximity to airports and populated areas, and operation within visual 

line of sight (VLOS) does not create a hazard to users of the NAS or the public or 

pose a threat to national security, and (2) whether a certificate of waiver, 

certificate of authorization, or airworthiness certification under 49 USC 44704 is 

required for the operation of civil (non-governmental) UASs. Therefore, if the 

Secretary determines that such vehicles “may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft in the national airspace system”. 

Epic Creative Overview 

EPIC Creative uses small UAS (quad-copters) weighing less than 6 lbs fully 

loaded (camera and battery). Quad-copters are small, agile UASs with the ability 

to hover and move in the vertical and horizontal planes simultaneously. EPIC 

Creative will operate only in visual line of sight (VLOS), and only in tightly 

controlled and limited airspace. The UASs are capable of operating at speeds of 

up to 29 knots, but are routinely operated at much lower speeds, usually at a 

standstill for imaging. They are most frequently operated below 200 feet above 

ground level (AGL), and never over 400 feet AGL. EPIC Creative/Miles Cooksy’s 

exemption request would permit a commercial operation of SUAS for aerial 

photography and videography in tightly controlled and limited airspace. Aerial 

photography and videography services will be offered to golf courses, 

residences, business to business marketing, and farming. All operations will be 

conducted on private property and with the written and/or oral permission of the 

property owner(s), and always with privacy in mind. Operations will always be 

conducted in areas that are clear of all people, except the pilot in command (PIC) 

and the PIC’s helper(s). Such operations will ensure that the SUAS will “not 

create a hazard to users of the national airspace system or the public”. 

Our Aircraft 
EPIC Creative/Miles Cooksy operates and uses the Inspire by DJI. DJI Inspire 1 

is controlled using a DJI transmitter, operating on a 2.4GHz frequency to a 

maximum range of 2km. (Specific operating range of 2.400-2.483GHz.) (See 

Manual Appendix page 57 for all specifications.) These specifications fall within

FCC guidelines for operators. Powered by a lithium polymer battery it has a 4 

hour time between charges. The DJI Inspire 1 transmitter has a built in GPS 

allowing the Inspire 1 to always know where to return to in the event of a failure. 

The Inspire 1 transmitter will be controlled by a single operator, but will utilize a 

Visual Observer when necessary. These highly advanced capabilities will ensure 

that the SUASs can be safely operated and “not create a hazard to users of the 

national airspace system or the public.” Due to the size of the SUAS and the 

tightly controlled and limited airspace in which the SUAS will operate, approval of 

this application presents no risk to national security. 

Equivalent Level of Safety

In an effort to join the FAA in its mission to provide the safest, most efficient 

aerospace system in the world and to minimize the risk to the NAS or to persons 

and property on the ground, EPIC Creative/Miles Cooksy agrees to be bound by 

the following limitations and conditions when conducting commercial operations 

under a FAA issued exemption: 

A. For the purposes of ensuring SUASs will be operated within the 

standards that the FAA has allowed in the AMA National Model Aircraft 

Safety Code: 

 SUASs will not be flown:

a. In a careless or reckless manner.

b. At a location where SUAS activities are prohibited. 

 SUAS pilots will:

a. Yield the right of way to all human-carrying aircraft.

b. See and avoid all aircraft and a spotter must be used when 

appropriate

 c. Not fly higher than 400 feet above ground level or within three (3) 

miles of an airport without notifying the airport operator.

 Not interfere with operations and traffic patterns at any airport, 

heliport or seaplane base except where there is a mixed use 

agreement. 

 Not exceed a takeoff weight of 55 pounds (including payload).

 Ensure the aircraft is identified by affixing the owner’s contact 

information to the outside of the SUAS. 

 Not operate SUASs while under the influence of alcohol or while 

using any drug that could adversely affect the PIC’s ability to safely 

control the model. 
 Not operate SUASs carrying pyrotechnic devices that explode or 

burn, or any device which propels a projectile or drops any object 

that creates a hazard to persons or property. 

B. SUASs will not be flown unless: 

 The aircraft, control system and pilot skills have successfully 

demonstrated all maneuvers intended or anticipated prior to the 

specific event. 

 An inexperienced pilot is assisted by an experienced pilot. 

C. All pilots shall avoid flying directly over unprotected people, vessels, 

vehicles or structures and shall avoid endangerment of life and property of 

others. 

 A successful radio equipment ground-range check in accordance 

with manufacturer’s recommendations will be completed before the 

first flight of a new or repaired model aircraft. 

 SUASs must use the radio-control frequencies currently allowed by 

the Federal Communications Commission (FCC). 

D. SUASs will not knowingly operate within three (3) miles of any preexisting flying site without a frequency-management agreement. 

E. Excluding takeoff and landing, no SUASs may be flown outdoors 

closer than 25 feet to any individual, except for the PIC and the PIC's 

helper(s) located at the takeoff site. 

F. Under no circumstances may a pilot or other person touch a SUAS in 

flight while it is still under power, except to divert it from striking an 

individual.

G. The PIC of the SUAS shall: 

 Maintain control during the entire flight, maintaining visual 

contact without enhancement other than by corrective lenses 

prescribed for the pilot. 

 Fly using the assistance of a camera or First-Person View (FPV) 

only in accordance with the procedures outlined in AMA 

Document #550. 

 Fly using the assistance of autopilot or stabilization system only 

in accordance with the procedures outlined in AMA Document 

#560. 

H. The flying area must be clear of all utility wires or poles and an SUAV 

will not be flown closer than 50 feet to any above-ground electric utility 

lines. 

I. The flying area must be clear before the engine is started, except for 

PIC and the spotter. 
In addition to the above rules outlined by the AMA National Model Aircraft Safety 

Code and in an effort to enhance the safety offered by the already safe 

operations mentioned above, EPIC Creative/Miles Cooksy also agrees to be 

bound by the following limitations and conditions: 

1. Flights will be operated within VLOS of the PIC. 

2. Maximum total flight time for each operational flight will be 18 minutes. 

Flights will be terminated at 25% battery power reserve should that occur 

prior to the 18 minute limit. 

3. The SUAS will only operate in tightly controlled and limited airspace. 

4. A briefing will be conducted in regard to the planned SUAS operations prior to 

each flight. It will be mandatory that all personnel who will be performing duties 

within the boundaries of the safety perimeter be present for this briefing. 

5. The PIC and the PIC’s helper(s) will have been trained in operation of SUAS 

and received up-to-date information on the particular SUAS to be operated. 

6. The pilot and the PIC's helper(s) will at all times be able to communicate by 

voice. 

7. If the SUAS loses communications or loses its GPS signal, the SUAS will have 

capability to return to a pre-determined location within the security perimeter

and safely land. 

8. The SUAS will have the capability to abort a flight in case of unpredicted 

obstacles or emergencies. 

9. All flights will be conducted on private property and with the written and/or oral 

permission of the property owner(s). 

10. Flights will always be conducted in areas that are clear of all people, except 

for the PIC and the PIC's helper(s). 

11. All flights will be conducted outdoors in visual meteorological conditions 

(VMC) and never during severe weather conditions. 

12. Flights will not occur in weather conditions that prevent the PIC from 

operating within visual line-of-sight (VLOS) at all times or in weather conditions 

that dramatically affect the UAS’s flight (e.g. high winds). 

13.If an operation occurs in an area where people could inadvertently enter the

area, an operational border will be established with traffic cones. If it’s not

feasible to use traffic cones due to interference with the 

photography/videography, the PIC's helper(s) will be responsible for keeping a

safe perimeter around the operation. The operation will cease immediately and 
be rescheduled if it’s impossible to establish a safe perimeter around the 

operation. 

14. The PIC will be responsible for logging all flights to ensure the 

comprehensive preventative maintenance plan can be followed, as described in 

the “Preventative Maintenance” section below. 

15. The SUAS will not be routinely operated in the proximity of any airports. In 

any cases where the SUAS must be operated within three (3) miles of an airport, 

the airport operator will be notified before the operation commences. The 

operation of SUASs, weighing less than 6 lbs., conducted in the strict conditions 

as outlined above, will provide an equivalent level of safety supporting the grant 

of exemptions requested herein, including exempting the applicant from the 

requirements of Part 21 and allowing commercial operations. These lightweight 

aircraft operate at slow speeds, close to the ground, and in a tightly controlled 

environment. As a result, they offer a much safer way to capture aerial 

photography and videography. Furthermore, the proposed operations represent a 

safety enhancement to the already safe operations that have been granted by 

the FAA for the establishment of the AMA National Model Aircraft Safety Code. 

Preflight Action Plan 

The PIC will follow a comprehensive pre-flight checklist to ensure that the SUAS 

is in a condition for safe flight. This plan will be improved as needed in order to 

ensure all known safety precautions and/or safety precautions suggested by the 

manufacturer are being accounted for. 

A. Pre-flight Inspection 

1. Check that the remote control, Inspire 1 battery(s), DJI controller, MiFi, 

Ipads and smartphone are all fully charged. 

2. Visually inspect the LIPO batteries for signs of wear or damage. Check 

both battery switches for proper operation. 

3. Turn the motor shafts with your fingers and verify they are smooth without 

excessive play or binding. 

4. Verify that the rotation diagram on the propellers matches the rotation 

diagram on the Inspire 1 arms. 

5. Inspect the propeller edges for nicks or cuts. 

6. Flex both sides of the propellers’ blades to check for hairline cracks where 

the blades connect in the center of the propeller. 

7. Verify that the landing gear is secure (not cracked/broken/loose). 

8. Verify that the retractable landing gear is functioning smoothly. 

9. Verify that the Micro-SD card has been inserted and formatted. 

10. Verify that the damping absorbers are not broken and/or worn.

11.Arm/Disarm motors three separate times to allow GPS to lock on the 

launch site.
12.Inspect the gimbal and camera for smooth operation.

13.Verify all trims and switches set at "0".

14.Verify video connection between the Inspire and the DJI controller. 

15.Perform final area check for obstructions. 

B. Power Up 

1. Verify that throttle is at "0" position.

2. Power on the equipment in the following order:

a. Power on the Inspire battery, check for four green lights. 

b. Power on the DJI controller, switch to MAP VIEW. 

3. Wait for a lock with 9 satellites. 

4. Calibrate the Inspire 1 compass. 

5. Place the Inspire on open, level ground with the battery indicators facing 

towards the PIC. 

C. Takeoff/Launch 

1. Verify that the remote control antenna is perpendicular to the ground 

(pointing skyward). 

2. Verify that the front of the Inspire 1 is pointing into the wind. 

3. Verify that the GPS is still connected to 9 or more satellites. 

4. Arm/Disarm motors and check that telemetry is correct. 

5. Advance throttle. 

6. Take off and hover at about 6-8 feet above the takeoff point to verify that 

the Inspire 1 has a solid GPS lock. If any abnormalities are noticed 

(drifting, flying in circles, etc.), land immediately and repeat the “Pre-flight 

Inspection” and “Power Up” sequences. 

7. Verify that the inspire 1 holds a steady position while yawing 360 degrees. 

8. Verify that the inspire 1 responds appropriately to all controls – yaw 

left/right, pitch forward/backward, roll left/right, and throttle up/down. 

D, Preventative Maintenance 

A comprehensive preventative maintenance plan will be followed in order to 

ensure the SUAS’s software is up-to-date, the batteries are in good health, and 

the aircraft itself is always ready for safe flight. (EPIC Creative/Miles Cooksy

follows suggested maintenance in attached DJI manual) 

E. Pilot in Command (PIC) Qualifications 

EPIC Creative/Miles Cooksy respectfully purposes that operator requirements 

should take into account the characteristics of the particular UAS. Certain UASs, 

such as the DJI Inspire 1 are characterized by a high degree of control and 

various built-in technical capabilities that limit the potential for operation outside 
of the operating conditions set forth above. Additional automated safety functions 

and safety enhancing features of the SUAS's include the following: 

 Auto-pilot detection of lost GPS or of insufficient satellites initiates an 

immediate return to aircraft take-off location ("home"). 

 Low power on the aircraft triggers escalating alarms at GCS. 

 If the auto-pilot detects a lost-link to the GCS, landing procedure begins. 

Given these safety features, EPIC Creative/Miles Cooksy proposes that 

operators of the SUAS should not be required to hold a commercial pilot 

certification. Instead, operators should be required to: 

 Hold a private pilot license and have a current medical certification. 

 Have completed the manufacturer's training or a minimum of 10 hours 

training program for operation of the SUAS's.

F. Privacy

 Since the areas being photographed or filmed will be on private property, 

accessed only after given written and/or oral consent by the property 

owner(s), and clear of all people, except for the PIC and the PIC's 

helper(s), approval of this application presents no risk to the public 

privacy. In addition, EPIC Creative/Miles will honor all requests for "no-fly 

zone". 

Public Interest 

Granting this exemption would benefit the public as a whole. SUASs offer a 

strong equivalent level of safety, a reduction in environmental impacts, and are 

free from the harmful emissions associated with the manned aircraft that are 

currently used for aerial photography and videography. Due to the size of the 

SUAS and the tightly controlled and limited airspace in which the SUAS will 

operate, approval of this application presents no risk to the public. Furthermore, 

the public will be able to legally acquire aerial photography and videography to 

help in, but not limited to, advertising homes for sale, advertising uninhabited 

home lots, business to business marketing and golf courses. 

Requested Exemptions 

EPIC Creative/Miles Cooksy requests exemption from the following regulations 

since it’s not possible to fully comply with them, and attempting to follow them for 

the purposes of operating a SUAS would be burdensome: 
Airworthiness Certificates

14 CFR Part 21, Subpart H

Subpart H establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR 91.203 (a) (1). Given the size and 

limited operating area associated with the aircraft to be utilized by Singer’s 

Creations, an exemption from Part 21 Subpart H meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 USC 44701 (f)) and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft from the requirement for an airworthiness 

certificate, upon consideration of the size, weight, speed, operational capability, 

and proximity to airports and populated areas of the particular SUAS. In all 

cases, an analysis of these criteria demonstrates that the SUAS operated without 

an airworthiness certificate, in the restricted environment and under the 

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

operating with an airworthiness certificate without the restrictions and conditions 

proposed. 

Medical certificates

14 CFR 61.23 (a)

This regulation requires pilots of manned aircraft to hold a medical certificate. 

Since risks associated with the operation of the proposed SUAS are so 

diminished from the level of risk associated with any manned aircraft; the SUAS 

is of a size, weight, speed, and operational capabilities which makes it much 

safer than any manned aircraft; since operations will occur in tightly controlled 

and limited airspace; and considering that all operations will be on private 

property that is clear of all people, obtaining and maintaining a medical certificate 

would not improve the safety of the operation. In the very rare case of a mishap, 

the SUAS being flown will pose significantly less of a threat than manned 

helicopters and fixed wing aircraft because the SUASs are a fraction of the size, 

a fraction of the weight, will be flown at a fraction of the speed, carry no 

flammable fuel, and carry no crew or passengers. 

Private pilot privileges and limitations: Pilot in command

14 CFR 61.113 (a) and (b)

These regulations limit private pilots to non-commercial operations. Because the 

SUAS will not carry a pilot or passengers; due to the SUAS’s size, weight, speed, 

and operational capabilities; and since operations will occur in tightly controlled 

and limited airspace, the proposed operations can achieve the equivalent level of 

safety of current operations that currently require a commercial pilot’s license.

Furthermore, since there are no standards for either private or commercial SUAS 

pilot certificates, knowledge of airspace regulations and dexterity in the control 

and operation of the SUAS acquired from actual operation of the aircraft will be 

the most important factors in establishing an equivalent level of safety. It cannot 

be assumed that a commercial pilot, approved to operate a manned helicopter or 

fixed wing aircraft, has the skill or ability to safely operate an unmanned aerial 
vehicle, operating at 400 feet AGL or lower, within strictly controlled preapproved airspace. 

Flight instruction

14 CFR 91.109

This regulation provides that no person may operate a civil aircraft (except a 

manned free balloon) that is being used for flight instruction unless that aircraft 

has fully functioning dual controls. SUASs and remotely piloted aircraft, by their 

design do not have fully functional dual controls. Flight control is accomplished 

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

communications. The FAA has approved exemptions for flight training without

fully functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft. The equivalent level of safety provided by the fact that 

neither a pilot nor passengers will be carried in the aircraft and by the size and 

speed of the aircraft. 

Altimeter settings

14 CFR 91.121

This regulation requires each person operating an aircraft to maintain cruising 

altitude by reference to an altimeter that is set “...to the elevation of the departure 

airport or an appropriate altimeter setting available before departure.” As the 

SUAS may not have a barometric altimeter, but instead a GPS altitude read out, 

an exemption may be needed. An equivalent level of safety will be achieved by 

the operator by confirming the altitude of the launch site shown on the GPS 

altitude indicator before flight. 

Fuel Requirements for Flight in VFR Conditions

14 CFR 91.151 (a)

This regulation prohibits an individual from beginning “a flight in an airplane 

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 – (1) During the day, to fly after that for at least 30 minutes; or (2) 

At night, to fly after that for at least 45 minutes.” The battery powering the SUAS 

provides approximately <25 minutes of powered flight. That would make it 

impossible to meet the 30 minute reserve requirement. Given the limitations on 

the SUAS’s proposed flight area and the location of its proposed operations 

within a predetermined area, a longer time frame for flight in daylight or night 

VFR conditions is reasonable. An equivalent level of safety can be achieved by 

limiting flights to <25 minutes or 25% of battery power (whichever occurs first). 

This restriction would be more than adequate to return the SUAS to its planned 

landing zone from anywhere in its limited operating area. 

Maintenance Inspections

14 CFR 91.405 (a); 14 CFR 91.407 (a)(1); 14 CFR 91.409 (a)(1); 14 CFR 91.409 

(a)(2); 14 CFR 91.417 (a) and (b)
These regulations require that an aircraft operator or owner “shall 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...,” 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. Maintenance will be accomplished by the operator 

pursuant to the aforementioned Inspire 1 user manual and guide. An equivalent 

level of safety will be achieved because these small SUASs are very limited in 

size, will carry a small payload, and operate only in restricted areas for limited 

periods of time. If mechanical issues arise, the SUAS can land immediately and 

will be operating from no higher than 400 feet AGL. As outlined in the 

aforementioned Pre-flight Action Plan, the operator will ensure that the SUAS is 

in working order prior to initiating flight and perform maintenance as required. 

Moreover, the operator is the person most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition to provide the equivalent 

level of safety. 

In accordance with 14 CFR Part 11, the following summary is provided for 

publication in the Federal Register:

The applicant seeks an exemption from the following rules: 14 CFR Part 21, 

Subpart H; 14 CFR 61.113 (a) and (b); 14 CFR 91.109; 14 CFR 91.121; 14 

CFR 91.151; (a); 14 CFR 91.405 (a); 14 CFR 91.407 (a)(1); 14 CFR 91.409 

(a)(1); 14 CFR 91.409 (a)(2); 14 CFR 91.417 (a) and (b) to commercially

operate small unmanned aircraft systems (55 lbs. or less) in order to safely

and legally capture aerial photography and videography for use by golf 

courses, residences, business to business marketing, and farming. 

The operation of SUASs conducted in the strict conditions outlined above, will 

provide an equivalent and/or greater level of safety supporting the grant of the 

exemptions requested herein, including exempting the applicant from the 

requirements of Part 21 and allowing commercial operations. These lightweight 

aircraft operate at slow speeds, close to the ground, and in a sterile environment, 

and as a result, are far safer than existing operations conducted with helicopters 

operating in close proximity to the ground, people, or other buildings in the 

vicinity. Given the small size of the SUASs involved, the slow speed at which 

they must be operated in order to capture photos and videos, and the restricted 

environment within which they will operate, the Inspire 1demonstrates that it can 

be operated within an equivalent level of safety in which Congress envisioned 

that the FAA must, by exemption, allow commercial operations of SUASs to 

commence immediately. Also, due to the size of the SUASs and the restricted 

areas in which the relevant SUASs will operate, approval of this application 

presents no threat to national security. Given the clear direction in Section 333 of 

the Reform Act, the authority contained in the Federal Aviation Act, the strong 

equivalent level of safety surrounding the proposed operations, the significant 

public benefit – including enhanced safety, reduction in environmental impacts, 
no emissions, ability to legally obtain aerial photography and videography 

services – the grant of the requested exemptions is in the public interest. 

Accordingly, EPIC Creative/Miles Cooksy respectfully requests that the FAA 

grant the requested exemption without delay. Satisfaction of the criteria provided 

in Section 333 of the Reform Act – size, weight, speed, operating capability, 

proximity to airports and populated areas, operation within the visual line of sight, 

public safety, and national security – provide more than adequate justification to 

grant EPIC Creative/Miles the requested exemption, allowing for commercial 

operations as described herewith. 

Sincerely, 

Miles Cooksy

EPIC Creative