UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No._________________

IIN THE MATTER OF THE PETITION FOR EXEMPTION OF:

MARSHA E COPELAND d.b.a. Overlook Aerials

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIRFEMENTS 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, DJI INSPIRE 1 AND YUNEEC TYPHOON G500 4K

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted	on	August	15,	2015

Marsha	E	Copeland	d.b.a.	Overlook	Aerials

28814	Sopris	Ln

San	Antonio,	TX	78260

Marsha@GVTC.com

210	860-6904
2

TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS 3

SUMMARY 4

INTRODUCTION AND INTERESTS OF PETITIONER 4

BACKGROUND 4

BASIS FOR PETITION 5

NAME AND ADDRESS OF PETITIONER 7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH MARSHA E. COPELAND D.B.A. 

OVERLOOK AERIALS

SEEKS EXEMPTION 8

THE EXTENT OF RELIEF MARSHA E. COPELAND D.B.A. OVERLOOK AERIALS SEEKS 

AND THE REASON MARSHA E. COPELAND D.B.A OVERLOOK AERIALS SEEKS THE 

RELIEF 11

THE REASONS WHY GRANTING MARSHA E. COPELAND D.B.A. OVERLOOK AERIALS’S 

REQUEST WOULD BE IN THE PUBLIC INTEREST 14

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY 17

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER 31

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT MARSHA E. COPELAND D.B.A. OVERLOOK AERIALS’ 

REQUEST 32

CONCLUSION 32

APPENDICES 33
3

GLOSSARY OF ABBREVIATIONS

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 Command

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

Section 333

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 
4

SUMMARY

Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	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 

Marsha E. Copeland d.b.a. Overlook Aerials to operate an Unmanned 

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

video and photography of construction sites, real estate, special events, film 

sets, corporate marketing and landscapes for visual data collection, wildlife 

monitoring, aerial surveying, remote sensing and educational picture 

production.

INTRODUCTION	AND	INTERESTS	OF	THE	PETITIONER

Marsha	E.	Copeland	d.b.a.	Overlook	Aerials will	provide	its	clients	with	

both	finished	documentary	and	promotional	digital	content	for	use	in	the	

marketing	of	real	estate	properties,	personal	events,	collection	of	data	for	

residential	or	industrial	development,	commercial	investment,	property	

inspections,	and	emergency	disaster	surveillance.		Marsha	E.	Copeland is	

a	licensed	Commercial	Instrument	Rated	Pilot	SEL with	a	thorough	

knowledge	of	the	NAS	environment	and	is	a	member	of	the	International	

Women	Pilots	Association	(The	99’s). Marsha	E.	Copeland	also	holds	a	

Ground	Instructor	Certificate.		Marsha	E.	Copeland is	also	a	licensed	

Realtor	in	the	state	of	Texas	and	member	of	the	National	Association	of	

Realtors,	Texas	Association	of	Realtors	and	is	a	Certified	Residential	

Specialist	with	over	400	hours	of	real	estate	education.		

BACKGROUND

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

Yuneec	Typhoon	G500	4K

Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	seeks	an	exemption	to	

operate	three	models	of	UAS	for	compensation	or	hire	within	the	NAS,	

the	DJI	Phantom	3,	the	DJI	Inspire	1	and	the	Yuneec	Typhoon	Q500	4K

• The	DJI	Phantom	3	has	a	maximum	gross	weight	of	

approximately	2.8	pounds,	is	a	vertical	takeoff	and	landing	

(VTOL)	Unmanned	Aircraft	(UA)	with	Ground	Control	

Station	(GCS)	utilizing	electronic	tablet	or	smart	phone	
5

systems.		The	DJI	Phantom	3	has	a	diagonal	dimension	of	

23.2”,	height	of	11.8	inches	and	a	maximum	speed	of	

approximately	30	knots	and	a	maximum	flying	height	of	400	

ft.		It	is	equipped	with	four	main	rotors	that	are	driven	by	

Lithium	Polymer	battery	powered	electric	motors.

• The	DJI	Inspire	1	has	a	maximum	gross	weight	of	6	lbs	7.5	

ounces,	a	length	of	17.3	inches,	width	of	17.7	inches,	height	

of	11.8	inches	and	a	maximum	speed	42	knots.	The	DJI	

Inspire	1	is	also	equipped	with	four	main	rotors	driven	by	a	

Lithium	Polymer	battery	electric	motor.

• The	Yuneec	Typhoon	Q500	4K	has	a	maximum	gross	weight	

of	1700g	(3.75	lbs),	is	9.54inx16.54.		It	is	equipped	with	four

main	rotors	driven	by	a	Lithium	Polymer	Battery	electric	

motor.

• Both	the	DJI	Phantom	3,	Inspire	1	and	Yuneec	Q500	4K

operated	by	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	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	Marketing.

Basis	For	Petition

Petitioner,	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials, pursuant to the 

provisions of the Federal Aviation	Regulations	(14	C.F.R.	§	11.61)	and	the	

FAA	Modernization	and	Reform	Act	of	012	(FMRA),	Section	333,	Special	

Rules	for	Certain	Unmanned	Aircraft	Systems,	hereby	petitions	the	

Administrator	to	commercially	operate	the	DJI	Phantom	3	UAS,	the	DJI	

Inspire	1	and	the Yuneec	Typhoon	Q500	4K	UAS	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),	1.405(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,	Petitioner’s	

operation	of	DJI	Phantom	3	UAS,	DJI	Inspire	1	UAS	and	Yuneec	Typhoon

Q500	4K	UAS	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.
6

Accordingly,	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	requests	relief	

from	Sections	91.405(a), 91.407(a)(1),	maintenance	that	only	apply	to	

aircraft	with	an	airworthiness	certificate.

Petitioner	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	submits	that	the	

requested	relief	is	proper	since	an	equivalent	level	of	safety	will	be	

ensured.	Petitioner	will	use	experienced	personnel	or	technicians	to	

perform	maintenance,	alterations,	or	preventive	maintenance	on	the	

Aircraft	using	the	methods,	techniques,	and	practices	prescribed	in	the	

operating	documents	(i.e.,	DJI	Phantom	3	User	Manual,	DJI	Inspire	1	User	

Manual,	Phantom	3	Pilot	Training	Guide,	DJI	Inspire	1	User	Manual,	DJI	

Inspire	1	Maintenance	Manual,	and	DJI	Inspire	1	Safety	Guidelines,	

Yuneec	Typhoon	Q500	4K	Instruction	Manual).	Furthermore,	Petitioner	

will	document	and	maintain	all	maintenance	records	for	the	Aircraft.

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

Private	pilot	privileges	and	limitations:	Pilot	in	command,	is	requested	by	

Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	to	the	extent	necessary	to	

allow	a	Pilot	in	Command	(PIC)	who	is	a	holder	of	a	private	pilot	

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	UAS,	DJI	Inspire	1	UAS	and	Yuneec	Typhoon	Q500	4K	UAS	in	

a	manner	consistent	with	this	exemption,	including	evasive	and	

emergency	maneuvers	maintaining	appropriate	distances	from	people,	

vessels,	vehicles	and	structures	and	adherence	to	requirements	of	

operating	in	the	National	Airspace	system.

Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	seeks	relief	from	Section	

91.7(a),	entitled	Civil	aircraft airworthiness,	because	the	DJI	Phantom	3	

UAS	,the	DJI	Inspire	1	UAS,	and	the	Yuneec	Typhoon	Q500	4K	UAS	do	not

require	an	airworthiness	certificate	in	accordance	with	14	C.F.R.	Part	21,	

Subpart	H.	As	such,	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	submits	

that	it	will	ensure	that	the	Aircraft	are	in	an	airworthy	condition,	prior	to	

every	flight,	by	determining	that	the	Aircraft	are	in	compliance	with	the	

operating	documents	and	that	the	Aircraft	are	in	a	condition	for	safe	

flight.

Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	also	seeks	an	exemption	from	
7

the	requirements	of	Section 91.121,	entitled	Altimeter	Settings,	as	the	

Aircraft	will	not	have	a	typical	barometric	altimeter	onboard.	However,	

altitude	information	of	the	Aircraft	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	

Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	operation	of	the	Aircraft	

within	visual	line	of	sight,	at	or	below	400	feet	AGL,	will	ensure	a	level	of	

safety equivalent	to	Section	91.121.

Additionally, Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	seeks	an	

exemption	from	the	requirements	of	Section 91.151(b),	entitled	Fuel	

requirements	for	flight	in	VFR	conditions.	Marsha	E.	Copeland	d.b.a.	

Overlook	Aerials	submits that	safety	will	not	be	affected	by	operation	of	

the	Aircraft	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	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.

In	accordance	with	14	C.F.R.	§	11.81,	Marsha	E.	Copeland	d.b.a.	Overlook	

Aerials	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:

Marsha	E.	Copeland	d.b.a.	Overlook	Aerials

28814	Sopris	Ln

San	Antonio,	TX	78260

(210)	860-6904

Email:	marsha@gvtc.com
8

B.	The	Specific	Sections	Of	14	C.F.R.	From	Which	Marsha	E.	Copeland	

d.b.a.	Overlook	Aerials	Seeks	Exemption

1.	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	Seeks	

Exemption	From	The	Requirements	Of	Section	61.113	(a)	And	

(b).

Section	61.113,	entitled	Private	pilot	privileges	and	limitations:	

Pilot	in	command,	subsections	(a)	and	(b)	prescribe	the	following,	

in	relevant	part:

(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.

(b)	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.

2.	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	Seeks	

Exemption	From	The	Requirements	Of	Section	91.7	(a).

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.

3.	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	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--

(i)	The	current	reported	altimeter	setting	of	a	station	along	

the	route	and	within	100	nautical	miles	of	the	aircraft;

(ii)	If	there	is	no	station	within	the	area	prescribed	in	
9

paragraph	(a)(1)(i)	of	this	section,	the	current	reported	altimeter	

setting	of	an	appropriate	available	station;	or

(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.	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials Exemption	From	

The	Requirements	Of	Section	91151	(b).

Section	91.151,	entitled	Fuel	requirements	for	flight	in	VFR	

conditions,	subsection (b),	states	the	following:

(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.		Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	Exemption	

From	The	Requirement	Of	Section	91.405(a).

Section	91.405,	entitled	Maintenance	required,	subsection	(a),	

states	the	following:

Each	owner	or	operator	of	an	aircraft—

(a)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.

6.	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	From	The	

Requirements	of	Section	91.407(a)(1)	Section91.407,	entitled	

Operation	after	maintenance,	preventive	maintenance,	rebuilding,	or	

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

(a)	No	person	may	operate	any	aircraft	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.

7.		Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	Seeks	Exemption	

From	The	Requirements	Of	Sections	91.409	(a)	(1)	And	91.409	

(a)	(2).

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

following:

(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	--

(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

(2)	An	inspection	for	the	issuance	of	an	airworthiness	certificate	in	

accordance	with	part	21	of	this	chapter.

8.		Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	Exemption	From	

The	Requirements	Of	Sections	91.417	(a)	And	91.417(b).

Section	91.417,	entitled	Maintenance	records,	subsections	(a)	and	

(b),	state	the	following:

(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:

(1)	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--

(i)	A	description	(or	reference	to	data	acceptable	to	the				

Administrator)	of the	work	performed;	and

(ii)	The	date	of	completion	of	the	work	performed;	and	

(iii)	The	signature,	and	certificate	number	of	the	person

approving the aircraft for return to service.

(2)	Records	containing	the	following	information:

(i)	The	total	time	in	service	of	the	airframe,	each	engine,	

each	propeller,	and	each	rotor.

(ii)	The	current	status	of	life-limited	parts	of	each	

airframe,	engine,	propeller,	rotor,	and	appliance.

(iii)	The	time	since	last	overhaul	of	all	items	installed	on	

the	aircraft	which	are	required	to	be	overhauled	on	a	

specified	time	basis.

(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.
11

(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.	

(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.

(b)	The	owner	or	operator	shall	retain	the	following	records	for	

the	periods prescribed:

(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.

(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.

(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

C.	The	Extent	Of	Relief	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials

Seeks	And	The	Reason	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials

Seeks	The	Relief.

1. Extent	Of	Relief	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials

Seeks	And	The	Reason	Marsha	E.	Copeland	d.b.a.	Overlook	

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

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	either	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	
12

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,	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials

submits	that	an	equivalent	level	of	safety	will	be	maintained	because	no	

PIC	will	be	allowed	to	operate	the	Aircraft	unless	that	PIC	possesses	at	

least	a	private	pilot	certificate	and	has	met	certain	flight-hour	and	

currency	requirements,	demonstrating	that	the	PIC	is	able	to	safely	

operate	the	Aircraft	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,	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	submits	that	all	

flights	of	the	Aircraft,	conducted by	the	PIC	pursuant	to	the	grant	of	this	

Petition:	(1)	will	be	incidental	to	Marsha	E.	Copeland	d.b.a.	Overlook	

Aerials	business;	and	(2)	will	not	carry	passengers	or	property	for	

compensation	or	hire.

2. Extent	Of	Relief	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials

Seeks	And	The	Reason	Marsha	E.	Copeland	d.b.a.	Overlook	

Aerials	Seeks	Relief	From	Section	91.7	(a)

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

requested	to the	extent	required	to	allow	Marsha	E.	Copeland	d.b.a.	

Overlook	Aerials	to	determine	that	the	Aircraft	are	in	airworthy	

condition	prior	to	every	flight	by	ensuring	that	the	UAS	is	in compliance	

with	the	operating	documents.

Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	seeks	the	requested	relief	

because	the	Aircraft	do	not	require	an	airworthiness	certificate	in	

accordance	with	14	C.F.R.	Part	21,	Subpart	H.	Therefore,	Marsha	E.	

Copeland	d.b.a.	Overlook	Aerials	will	ensure	that	the	Aircraft	are	in	

airworthy	condition	based	upon	its	compliance	with	the	operating	

documents	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	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials

Seeks	And	The	Reason	Marsha	E.	Copeland	d.b.a.	Overlook	

Aerials	Seeks	Relief	From	Section	91.121
13

Relief	from	Section	91.121,	entitled	Altimeter	settings,	may	be	required	

to	allow	flight	operations	of	the	Aircraft,	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	level	(AGL),	Marsha	E.	Copeland	d.b.a.	

Overlook	Aerials	seeks	the	requested	relief	because	the	Aircraft’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	maintained	since	the	

Aircraft	are	equipped	with	GPS	equipment,	which	automatically	ensures	

that	a	ground	level	setting	will	be	established	prior	to	each	flight,	and	

provides	the	PIC	with	altitude	information	of	the	UA	on	the	heads-up	

display	of	the	GCS.

4.	Extent	Of	Relief	Marsha	E.	Copeland	d.b.a.	Overlook	

Aerials	Seeks	And	The	Marsha	E.	Copeland	d.b.a.	Overlook	

Aerials	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	Aircraft	during	daylight	hours	in	visual	meteorological	

conditions	(VMC),	under	visual	flight	rules	(VFR),	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.

Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	seeks	the	requested	relief	

because	without	an	exemption from	Section	91.151(b),	the	flight	time	

duration	of	the	battery	powered	Aircraft	will	severely	constrain	the	

practicality	of	any	aerial	video	or	still	photo	flight	operations that	

Marsha	proposes	to	conduct	pursuant	to	this	Petition.

Significantly,	as	set	forth	below,	the	technical	specifications	of	the	

Aircraft, the	operating	documents	of	the	Aircraft,	and	Marsha	E.	

Copeland	d.b.a.	Overlook	Aerials	proposed	operating limitations,	ensure	

that	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials will	safely	operate	the	
14

battery	powered	Aircraft 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.	Extent	of	Relief	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials

Seeks	And	The	Reason	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials

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,	

Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	requests	relief	from	these	

Sections	because	the	DJI	Phantom	3	UAS,	DJI	Inspire	1	UAS	and	Yuneec	

Typhoon	Q500	4K	UAS	do	not	require	airworthiness	certificates.	As	set	

forth	more	fully	below	the	Petitioner’s	aircraft	meets	the	conditions	of	

FMRA	Section	333	for	operation	without	an	airworthiness	certificate.	

Accordingly,	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	will	use	trained	

technicians	to perform	maintenance,	alterations,	or	preventive	

maintenance	on	the	UAS	using	the methods,	techniques,	and	practices	

prescribed	in	the	UAS	operating	documents	(i.e.,	DJI Phantom	3	User	

Manual,	DJI	Inspire	1	User	Manual,	and	the Yuneec	Typhoon	Q500	4K	

Instruction	Manual).	Furthermore,	Marsha	E.	Copeland	d.b.a.	Overlook	

Aerials	will	document	and	maintain	all maintenance	records	for	the	

Aircraft.

D.	The	Reasons	Why	Granting	Marsha	E.	Copeland	d.b.a.	Overlook	

Aerials	Request	Would	Be	In	The	Public	Interest	and	How	It	Would	

Benefit	The	Public	As	A	Whole.

Granting	the	present	Petition	will	further	the	public	interest	by	allowing

Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	to	safely,	efficiently,	and	

economically	perform	aerial	video	and	photography	of	client	sites,	

events,	and	landscape	over	certain	areas	of	the	United	States.

Additionally,	use	of	the	Aircraft	will	decrease	congestion	of	the	NAS,	

reduce pollution,	and	provide	significant	benefits	to	the	economy.	

Notably,	the	benefits	of	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials

proposed	operation	of	the	Aircraft	would	be	realized	without	implicating

any	privacy	issues.
15

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

The	Aircraft	are	battery	powered	and	serve	as	a	safe,	efficient,	and	

economical	alternative	to	the	licensed	piloted	aircraft	traditionally	

utilized	to	obtain	aerial	imagery.	By	reducing	the	amount	of	manned	

aircraft	needed	to	perform	aerial	acquisitions,	an	exemption	allowing	

the	use	of	Petitioner’s	UAS’s	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.	Marsha	E.	

Copeland	has	in	the	past	flown	fixed-wing	aircraft	to	observe	real

estate	conditions.	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	Aircraft	do	not	

require	an	airport	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,	The	DJI	Inspire	1	UAS	and	the Yuneec	Typhoon

Q500	4K	UAS.

Conducting	aerial	acquisitions	with	the	UAS	Aircraft,	instead	of	

manned	aircraft,	will	greatly	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	petitioner’s	UASs	will	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	gallons	per	hour	of	aviation	fuel.	The	Petitioners’	

UASs,	while	reducing	the	carbon	footprint	of	aerial	acquisitions,	also

eliminate	noise	pollution,	as	the	UASs are	propelled	by	battery	

powered	electric	motors,	rather	than	an	internal	combustion	engine.
16

By	using	UAS	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	operations,	will	be	substantially	

reduced	or	completely	eliminated.	Aside	from	the	lack	of flight	crew	

members	located	onboard	the	aircraft,	the	DJI	Phantom	3,	the	DJI	

Inspire	1	UAS	and	the Yuneec	Typhoon	Q500	4K have	less	physical	

potential	for	collateral	damage	to	life	and	property	on	the	ground,	and	

in	the	air,	compared	to	the	heavier	manned	aircraft	that	typically	

conduct	similar	operations.

3.	Performing	Aerial	Video	and	Photography	Operations	With	

UAS	Will	Benefit	The	Economy.

In	addition	to	being	safe	and	efficient,	the	petitioner’s	UAS	are	also	an	

economical	alternative	to	using	manned	aircraft	to	conduct	similar	

aerial	operations.	As	such,	operation	of	the	UAS	such	as	the	

Petitioners’	aircraft	will	allow	United	States	based	companies,	like	

Marsha	E.	Copeland	d.b.a.	Overlook	Aerials,	to	remain	competitive	and	

contribute	to	growth	of	the	U.S.	economy.	Operating	the	battery	

powered	Aircraft	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	UAS	such	as	the	

petitioner’s	aircraft,	companies	such	as	Marsha	E.	Copeland	d.b.a.	

Overlook	Aerials,	can	remain	competitive	and	profitable,	and	

therefore,	provide	greater	job	stability	to	employees	and	contractors,	

which	will	ultimately	contribute	to	growth	of	the	U.S.	economy.	

Improved	financial	performance	of	U.S.	companies,	through	

commercial	use	of	the	UAS,	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

Similar	to	the	manned	aerial	acquisition	flight	operations	that	have	

been	conducted	for	decades,	Marsha	E.	Copeland	d.b.a.	Overlook	

Aerials	proposed	operation	of	the	Aircraft	will	not	implicate	any	

privacy issues.	Specifically,	the	Aircraft	will	be	operated	only	in	

compliance	with	operating	documents	which	requires	property	

owner	involvement	as	well	as	local	law	enforcement	notification	
17

where	required,	and	in	accordance	with	the	Federal	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	

Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	Seeks	Exemption.

1.	Reasons	Why	Petitioner’s	UAS	Meets	The	Conditions	Of	The

FAA	Modernization	and	Reform	Act	of	2012	(FMRA)	Section	

333.

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

associated	with	the	unmanned	aircraft	and	its	operation,	Marsha	E.	

Copeland	d.b.a.	Overlook	Aerials	operation	of	the	Aircraft	meets	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	

section	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	
18

national	security;	and

(2)	Whether	a	certificate	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	national	airspace	system.

In	seeking	this	exemption,	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials

submits	that	the	Aircraft	can	operate	safely	in	the	NAS	pursuant	to	

FMRA	Section	333,	as	demonstrated	by:	(a)	the	characteristics	of	the	DJI	

Phantom	3	UAS,	DJI	Inspire	1	UAS,	and	the Yuneec	Typhoon	Q500	4K;	

(b)	the	pilot	certification	requirement;	and	(c)	the	specific	operating	

limitations.

a.		The	Specifications	Of	The	DJI	Phantom	3	UAS,	the	DJI	

Inspire	1	UAS,	and	the Yuneec	Typhoon	Q500	4K	Demonstrate	

Their	Safe	Characteristics.

The	DJI	Phantom	3	UAS,	the	DJI	Inspire	1	UAS,	and	the Yuneec	Typhoon

Q500	4K	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, the	DJI	

Inspire	1	UAS,	and	the	Yuneec	Typhoon	Q500	4K

Demonstrate	Its	Safe	Characteristics

					The	DJI	Phantom	3,	DJI	Inspire	and	Yuneec	Typhoon	Q500	4K

specifications	and	Data	Sheet,	attached	as	Exhibit	A,	B	&	C,	set	the	

technical	specifications	of	the	UASs.

ii.	The	DJI	Phantom	3	UAS, the	DJI	Inspire	1	UAS	and	the

Yuneec	Typhoon	Q500	4K	UAS	Autonomous	Flight	And	

Navigation	Modes	Enable	The	UAS	To	Remain	Within	A	

Defined	Operational	Area.
19

					The	DJI	Phantom	3	UAS,	the DJI	Inspire	1	UAS,	and	the	Yuneec	

Typhoon	Q500	4K	UAS	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	UAS	is	provided	at	pages	11-17	

and	40-46	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,	and	the	

Yuneec	Typhoon	Q500	4K	pages	13-20	in	Exhibit	E.

iii.	The	DJI	Phantom	3	UAS,	DJI	Inspire	1	and	YUNEEC	

Typhoon	500G	4K	Are 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,	both	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	the	takeoff	position	and	

shutdown.

A	complete	description	of	the	Failsafe	Functions	of	the	DJI	Phantom	3

UAS	is	set	forth	at	pages	12	-14,	for	the	DJI	Inspire	1 at	pages	13 –	15,	

and	for	the	Yuneec	Typhoon	Q500	4K	page17	of	the	respective	User	

Manuals	attached	hereto	as	Exhibit	C,	D	&	E.

iv.	The	DJI	Phantom	3,	DJI	Inspire	1	and	Yuneec	

Typhoon	Q500	4K	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	23	through	38	of	the	DJI	Phantom	3	User	Manual,	pages	40	

through	47	of	the	DJI	Inspire	1	User	Manual	and	pages	13-18	of	the	

Yuneec	Typhoon	Q500	4K	Instruction	Manual.	DJI	Phantom	3,	DJI	Inspire	

1	and	Yuneec	Typhoon	Q500	4K	Manuals	are	attached	hereto	as	Exhibits	

C,	D	&	E.
20

a.	Flight	Operations	Of	DJI	Phantom	3,	DJI	Inspire	1	and	

Yuneec	Typhoon	Q500	4K	UASs	Are Limited	To	The	Line	Of	

Sight	Of	A	Certificated	Pilot	in	Command	With A	Safety	

Observer.

Marsha	E.	Copeland	d.b.a.	Overlook	Aerials	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,	the	DJI	Inspire	1	and	

the Yuneec	Typhoon	Q500	4K	UAS.	Additionally,	a	safety	observer	will	

assist	all	pilots during	flight	time.

b.	Flights	Of	DJI	Phantom	3,	DJI	Inspire	1	and	Yuneec	Typhoon

Q500	4K	UAS	Will	Be	Conducted Pursuant	To	Specific	

Operating	Limitations.

In	seeking	this	exemption,	Marsha	E.	Copeland	d.b.a.	Overlook	Aerials

proposes	to	commercially	operate DJI	Phantom	3,	DJI	Inspire	1	and	

Yuneec	Typhoon	Q500	4K	UAS	for	the	special	purpose	of	conducting	

aerial	video and	photography	over	certain	areas	of	United	States,	

pursuant	to	the	following	specific operating	limitations:

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

the	following aircraft	described	in	the	operating	documents,	

rotorcraft	UAS	weighing	less	than	55	pounds	maximum	gross	weight:	

DJI	Phantom	3,	DJI	Inspire	1	and	Yuneec	Typhoon	Q500	4K

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	20k.

4.	The	UAS	must	be	operated	at	an	altitude	of	no	more	than	400	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	FAA-issued	airman medical	certificate.

6.	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	
21

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	must	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.

7.	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.

8.	The	operating	documents	and	the	grant	of	exemption	must	be	

accessible	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	operator’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.

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

condition	for	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	

maintenance	and	alterations	must	be	properly	documented	in	the	

aircraft	records.

10.	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	
22

conducts	the	functional	test	flight	must	make	an	entry	in	the	aircraft	

records.

11.	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.

12.	The	operator	must	follow	the	UAS	manufacturer’s	

aircraft/component, maintenance,	overhaul,	replacement,	inspection,	

and	life	limit	requirements.

13.	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.

14.	Each	UAS operated	under	this	exemption	must	comply	with	all	

manufacturer	Safety	Bulletins.

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

the	corrective	action	taken	against	discrepancies	discovered	between	

inspections.

16.	The	PIC	must	possess	at	least	a	private	pilot	certificate	and	at	least	a	

current third-	class	medical	certificate.

17.	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.

18.	UAS	operations	may	not	be	conducted	during	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	
23

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.

19.	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	management	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.

20.	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.

21.	If	the	UA	loses	communications	or	loses	its	GPS	signal,	it	must	return	

to	a	predetermined location	within	the	planned	operating	area	and	

land	or	be	recovered in	accordance	with	the	operating	documents.

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

emergencies	in	accordance	with	the	operating	documents.

23.	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.

24.	The	operator	must	obtain	an	Air	Traffic	Organization	(ATO)	issued	

Certificate	of	Waiver	or	Authorization	(COA)	prior	to	conducting	any	

operations	under	the	grant	of	exemption.	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.

25.	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.

26.	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	requirements.
24

27.	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	AS	is	operating.	These	documents	must	be	made	available	to	

-the Administrator	or	any	law	enforcement	official	upon	request.

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

aviation	operations	and	activities	at	all	times.

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

vehicle.

30.	Flight	operations	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	on

participating	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	those	persons	per	§	

91.119(a).

31.		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.

32.	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	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.
25

2.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	

61.113(a) And	(b)	Would	Not	Adversely	Affect	Safety.

Marsha	E.	Copeland	d.b.a	Overlook	Aerials	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,

DJI	Inspire	1,	and	the Yuneec	Typhoon	Q500	4K	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	3	or	

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	the	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,	the	DJI	Inspire	1	or	the	

Yuneec	Typhoon	Q500	4K UAS,	Marsha	E.	Copeland	d.b.a	Overlook	

Aerials	submits	that	the	additional manned	airmanship	experience	of	a	

commercially	certificated	pilot	would	not correlate	to	the	airmanship	

skills	necessary	for	the	Petitioner’s	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).

Marsha	E.	Copeland	d.b.a	Overlook	Aerials	will	not	allow	any	PIC	to	

operate	the	DJI	Phantom	3, the	DJI	Inspire	1,	or	the Yuneec	Typhoon

Q500	4K UAS	unless	that	PIC	has	demonstrated,	by	meeting	minimum	

flight-hour requirements	or	the	training	and	currency requirements,	that	

the	PIC	is	able	to	safely	operate	the	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	
26

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	the	Petitioner’s	proposed	

operations.	The Administrator	has	held	that	prior	documented	flight

experience	that	was	obtained in compliance	with	applicable	regulations	

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	minimum	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	

currency	purposes).	The	FAA	finds	that	at	a	minimum,	the	flight-hour	

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	experiencebuilding	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.
27

Exemption	No.	11138	at	page	15. Accordingly,	Marsha	E.	Copeland	d.b.a	

Overlook	Aerials	will	ensure	safe	operations	by	not	allowing	any PIC	to	

operate	the	DJI	Phantom	3,	DJI	Inspire	1,	or	the	Yuneec	Typhoon	Q500	

4K	UAS	unless	that	PIC	has demonstrated,	by	meeting	minimum	flighthour	and	currency	requirements,	that the	PIC is	able	to	safely	operate	

UASs	in	a	manner consistent	with	the	exemption,	including	evasive	and	

emergency	maneuvers	and maintaining	appropriate	distances	from	

people,	vessels,	vehicles	and	structures.

3.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	

91.7(a) Would	Not	Adversely	Affect	Safety.

The	equivalent	level	of	safety	established	by	Section	91.7(a)	will	be	

maintained because	prior	to	every	flight,	Marsha	E.	Copeland	will	ensure	

that	the	DJI	Phantom	3, the	DJI	Inspire	1,	or	the Yuneec	Typhoon	Q500	

4K	UAS	is	in	an	airworthy	condition	based	upon	the	UAS	incompliance	

with	its	operating	documents	and	as	stated	in	the	conditions	and

limitations	herein.

Additionally,	the	FAA	has	previously	granted	relief	from	Section	91.7(a)	

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,	11157,	11158,	11159,	11160,	11161).

4.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	

91.121 Would	Not	Adversely	Affect	Safety.

The	equivalent	level	of	safety	established	by	Section	91.121	will	be	

maintained because	the	altitude	information	of	the	DJI	Phantom	3, the	

DJI	Inspire	1,	and	the Yuneec	Typhoon	Q500	4K	UASs	will be	provided	to	

the	PIC	via	GPS	equipment	and	a	radio	communications	telemetry data	

link,	which	downlinks	from	the	UA	to	the	GCS	for	active	monitoring	of	

the flight	path	and	altitude.	This	altitude	information,	combined	with	the

operation	of	the	UASs	within	visual	line	of sight,	at	or	below	400	feet	

AGL,	will	ensure	a	level	of	safety	equivalent	to	Section 91.121.	The	

altitude	information	will	be	generated	by	GPS	equipment	installed

onboard	the	aircraft.	Prior	to	each	flight,	a	zero	altitude	initiation	point	is
28

automatically	established	by	the	UAS	at	ground	level.

The	FAA	has	previously	granted	relief	from	Section	91.121	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,	11112,	11136, 11138, 11150,	11153,	11156,	11157,	

11158,	11159,	11160,	11161).

5.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	

91.151(b) Would	Not	Adversely	Affect	Safety.

A	grant	of	this	exemption	would	ensure	an	equivalent	level	of	safety	

established	by	14	C.F.R.	Section	91.151(b)	as	a	result	of	(1)	the	technical	

specifications	of	the	Phantom	3,	DJI	Inspire	1,	and	the Yuneec	Typhoon

Q500	4K	UAS;	(2)	the	limitations	on	the	proposed	flight operations;	and	

(3)	the	location	of	the	proposed	flight	operations.	Accordingly, Marsha	E.	

Copeland	d.b.a	Overlook	Aerials	will	ensure	that	it	will	safely	operate	the	

battery	powered	DJI Phantom	3	and	DJI	Inspire	1	UASs	during	daylight	

hours	in	VFR	conditions,	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.

Here,	as	in	Exemption	No.	11109,	the	technical	specifications	of	the	DJI	

Phantom	3,	DJI	Inspire	1,and	the Yuneec	Typhoon	Q500	4K	UASs;	the	

limitations	on	the	proposed	flight	operations;	and the	location	of	the	

proposed	operations,	will	ensure	an	equivalent	level	of	safety	

established	by	14	C.F.R.	Section	91.151(b).	Furthermore,	safety	will	be	

ensured	as the	UASs	provide	audible	and	visual	warnings	to the	PIC	at	

the	GCS	when	the	UASs	experiences	low	battery	voltage.

Significantly,	previous	exemptions	granted	by	the	FAA	concerning	

Section	91.151 establish	that	safety	is	not	adversely	affected	when	the	

technical	characteristics	and operating	limitations	of	the	UAS	are	

considered.	Relief	has	been	granted	for manned	aircraft	to	operate	at	

less	than	the	minimums	prescribed	in	Section	91.151, including	

Exemption	Nos.	2689,	5745,	and	10650.	Moreover,	the	FAA	has

previously	granted	relief	from	Section	91.151	specific	to	UAS,	in	

circumstances similar,	in	all	material	respects,	to	those	presented	herein	
29

(e.g.	Exemption	Nos. 8811,	10808,	10673,	11042,	11062,	11063,	11064,	

11065,	11066,	11067,	11080, 11109,	11110,	11136,	11138,	11150,	

11153,	11156,	11157,	11158,	11159,	11160, 11161).

6.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Sections

91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	And	91.417(a)	&	(b)	

Would	Not Adversely	Affect	Safety.

In	seeking	this	exemption,	Marsha	E.	Copeland	d.b.a	Overlook	Aerials

submits	that	the level	of	safety	with	regard	to	the	regulatory	

maintenance	and	alteration requirements	established	by	Sections	

91.405(a),	91.407(a)(1), 91.409(a)(1)	&	(a) (2),	and	91.417(a)	&	(b)	will	

be	met	because	Marsha	E.	Copeland	d.b.a	Overlook	Aerials	will	use	

trained technicians	to	perform	maintenance,	alterations,	or	preventive	

maintenance	on	the UASs	using	the	methods,	techniques,	and	practices	

prescribed	in	the	operating documents. Furthermore,	Marsha	E.	

Copeland	d.b.a	Overlook	Aerials	will	document	and	maintain	all	

maintenance	records for	the	DJI	Phantom	3	the	DJI	Inspire	1,	and	the	

Yuneec	Typhoon	Q500	4K	UASs.

Since	the	DJI	Phantom	3, the	DJI	Inspire	1,	and	the Yuneec	Typhoon	Q500	

4K	UASs	will	be	inspected	as	prescribed by	the	operating	documents,	

Marsha	E.	Copeland	d.b.a	Overlook	Aerials	will	maintain	the	equivalent	

level	of safety	established	by	Sections	91.405(a),	91.409(a)(1),	and	

91.409(a)(2).	A	copy	of the	DJI	Phantom	3,	DJI	Inspire	1	and	the	Yuneec	

Typhoon	Q500	4K User	Manuals	are	attached	hereto	as	Exhibit C,	D	&	E.

The	exemption	sought	will	not	adversely	affect	safety	because	Marsha	E.	

Copeland	d.b.a.	Overlook	Aerials	will	use	trained	technicians	to	perform	

maintenance,	alterations	or	preventive maintenance	on	the	UASs	using	

the	methods,	techniques,	and	practices	prescribed by	the	operating	

documents.

Furthermore,	the	exemption	sought	would	maintain	an	equivalent	level	

of	safety established	by	Sections	91.407,	91.417(a)	and	91.417(b),	

because	all	maintenance of	the	DJI	Phantom	3, the	DJI	Inspire	1	and	the

Yuneec	Typhoon	Q500	4K UASs	will	be	performed	by	trained

technicians.	Maintenance	will	be	documented	and	maintained	utilizing	

the	monthly maintenance	log.
30

Significantly,	previous	exemptions	granted	by	the	FAA	concerning	

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

(b)	establish	that safety	is	not	adversely	affected	when	the	technical	

characteristics	and	operating limitations	of	the	UAS	are	considered.

In	consideration	of	Petitioner’s	proposed	operating	limitations,	the

operating	documents,	and	the	technical	aspects	of	the	DJI	Phantom	3, the	

DJI Inspire	1	and	the	Yuneec	Typhoon	Q500	4K UASs,	Marsha	E.	

Copeland	d.b.a	Overlook	Aerials	submits	that	safety	will	not	be	adversely	

affected by	granting	exemption	from	14	C.F.R.	Sections	91.405(a),	

91.407(a)(1)	and	(a)(2), 91.409(a)	(2),	and	91.417(a)	and	(b).	The	FAA	

has	previously	granted	relief 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,	

11157,	11158, 11159,	11160,	11161)

7.	The	FAA	May	Prescribe	Any	Other	Conditions	For	Safe	Operation.

In	accordance	with	Section	333	of	the	FAA	Modernization	and	Reform	

Act	of	2012 (FMRA)	and	14	C.F.R.	§	21.16	entitled	Special	Conditions,	

Marsha	E.	Copeland,	d.b.a	Overlook	Aerials requests	that	the	FAA	

prescribe	special	conditions	for	the	intended	operation	of	the DJI	

Phantom	3, the	DJI	Inspire	1,	and	the	Yuneec	Typhoon	Q500	4K	UASs,	

which	contain	such	safety	standards	that	the	Administrator	finds	

necessary	to	establish	a	level	of	safety	equivalent	to	that	established	by	

14	C.F.R.	Part	21,	Subpart	H,	and	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),	

and91.417(a)	&	(b).	Such	special	conditions	will	permit	safe	operation	of	

the	UAs	for	the	limited	purpose	of	conducting	aerial	video	and	

photography	over	certain	areas	of	the	United	States	for	compensation	or	

hire.	FMRA	Section	333	sets	forth	the	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;	and	further,	provides	the	

authority	for	such	UAS	to	operate	without	airworthiness	certification	in	

accordance	with	any	requirements	that	must	be	established	for	the	safe	

operation of	the	UAS	in	the	NAS.	Likewise,	the	Administrator	may	

prescribe	special conditions	pursuant	to	14	C.F.R.

§	21.16,	for	operation	of	the	DJI	Phantom	3,	the	DJI	Inspire	1,	and	the

Yuneec	Typhoon	Q500	4K	UASs,	since	the airworthiness	regulations	of	
31

14	C.F.R.	Part	21	do	not	contain	adequate	or appropriate	safety	

standards,	due	to	the	novel	or	unusual	design	features	of	the aircraft.	

Section	21.16,	entitled	Special	Conditions,	states	the	following:

If	the	FAA	finds	that	the	airworthiness	regulations	of	this	subchapter	do	

not	contain	adequate	or	appropriate	safety	standards	for	an	aircraft,	

aircraft	engine,	or	propeller	because	of	a	novel	or	unusual	design	feature	

of	the	aircraft,	aircraft	engine	or	propeller,	he	prescribes	special	

conditions	and	amendments	thereto	for	the	product.	The	special	

conditions	are	issued	in	accordance	with	Part	11	of	this	chapter	and

contain	such	safety	standards	for	the	aircraft,	aircraft	engine	or	propeller	

as	the FAA	finds	necessary	to	establish	a	level	of	safety	equivalent	to	that	

established	in the	regulations.

See	14	C.F.R.	§	21.16.

Therefore,	in	accordance	with	FMRA	Section	333	and	14	C.F.R.	§	21.16,	

the	FAA may	prescribe	special	conditions	for	intended	operation	of	the	

DJI Phantom	3, the	DJI	Inspire	1	and	the Yuneec	Typhoon	Q500	4K UASs,	

which	contain	such	safety	standards	that	the Administrator	finds	

necessary	to	establish	a	level	of	safety	equivalent	to	that established by	

14	C.F.R.	Part	21,	Subpart	H,	and	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).

A	Summary	That	Can	Be	Published	In	The	Federal	Register,	stating:	

The Rules	From	Which	Marsha	E.	Copeland,	d.b.a	Overlook	Aerials

Seeks	Exemption:

Marsha	E.	Copeland	d.b.a	Overlook	Aerials	seeks	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).

A	Brief	Description	Of	The	Nature	Of	The	Exemption	Marsha	E.	

Copeland	d.b.a	Overlook	Aerials	Seeks:

This	exemption	will	permit	Marsha	E.	Copeland	d.b.a	Overlook	Aerials	to

commercially	operate	an Unmanned	Aircraft	System	(UAS)	for	the	purpose	

of	conducting	aerial	video	and photography	over	certain	areas	of	the	
32

United	States.

Any	Additional	Information,	Views,	Or	Arguments	Available	To	

Support Marsha	E.	Copeland	d.b.a	Overlook	Aerials ’s	Request.

This	Petition	is	made	pursuant	to	the	FAA	Modernization	and	Reform	Act	

of	2012 (FMRA)	Section	333,	which	directs	the	Secretary	of	

Transportation	to	determine	if certain	UASs	may	operate	safely	in	the	

NAS.	As	such,	Marsha	E.	Copeland	d.b.a	Overlook	Aerials request for	

exemption	may	be	granted	pursuant	to	the	authority	of	FMRA	Section	

333	and 14	C.F.R.	Part	11,	as	set	forth	above.

FMRA	Section	333	sets	forth	the	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;	and	further,	provides	the	authority	for	

such	UAS	to	operate without	airworthiness	certification.

As	discussed	in	detail	above,	Marsha	E.	Copeland	d.b.a	Overlook	Aerials	

will	operate	the	DJI	Phantom	3, the	DJI	Inspire	1,	and	the	Yuneec	

Typhoon	Q500	4K	UASs	safely	in	the	NAS,	without	creating	a	hazard	to	

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

security.

CONCLUSION

As	set	forth	herein,	Marsha	E.	Copeland	d.b.a Overlook	Aerials	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,	the	DJI	Inspire	1	and	the	Yuneec	

Typhoon	G500	4K UASs	commercially,	without	an	airworthiness	

certificate,	for	the	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	Marsha	E.	

Copeland	d.b.a	Overlook	Aerials	to	safely, efficiently,	and	economically	

operate	the	DJI	Phantom	3, the	DJI	Inspire	1	and	the	Yuneec	Typhoon	

G500	4K	UASs commercially	within	the	NAS.

WHEREFORE,	in	accordance	with	the	Federal	Aviation	Regulations	and	
33

the	FAA Modernization	and	Reform	Act	of	2012,	Section	333,	Marsha	E.	

Copeland	d.b.a	Overlook	Aerials	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	Marsha	E.	Copeland	d.b.a	Overlook	Aerials	to	operate	

the	DJI	Phantom	3,	the	DJI	Inspire	1,	and	the	Yuneec	Typhoon	Q500	4K

UASs commercially	for	the	purpose	of	conducting	aerial	video	and	

photography	over certain	areas	of	the	United	States.

August	15,	2015

Respectfully	submitted,

Marsha	E.	Copeland,	d.b.a	Overlook	Aerials

Appendices:

A	-	DJI	Phantom	3	Specifications	Data	Sheet

B -	DJI	Inspire	1	Specifications	Data	Sheet

C	- Yuneec	Typhoon	Q500	4K	Specifications	Data	Sheet

APPENDIX	–	A

DJI	Phantom	3	TECHNICAL	SPECIFICATIONS

Marsha	E.	Copeland	d.b.a	Overlook	Aerials	will	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	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)

Aircraft

Name:	Phantom	3

Supported	Battery	–	DJI	6000mAH	LiPo	Battery

Weight	(Battery	&	Propellers	Included)	–12802g)

Hover	Accuracy	(Ready	to	Fly)	–	Vertical:	.8m;	Horizontal:	2.5m

Max	Yaw	Angular	Velocity	-	2000/s
34

Max	Tilt	Angel	-	350

Max	Ascent	Speed	–	6m/s

Max	Descent	Speed	–	2m/s

Max	Flight	Speed	–	15m/s	(NOT	RECOMMENDED)

Gimbal

Working	Current	– Static:	750mA;	Dynamic:	900mA	1.1.2.2	Control	

Accuracy	-	±0.030

Controllable	Range	–	Pitch:	-900	-	00

Maximum	Angular	Speed	–	Pitch:	900/s

Camera

Operating	Temperature	Range	-	320F	-	1040F	(00C	-	400C)

Sensor	Size	–	1/2.3”

Effective	Pixels	–	14M

Resolution –	4384x3288

HD	Video	Recording	–	1080p30	&	720p

	Recording	Field	of	View	-	1100/850

Transmitter

Operating	Frequency	–	5.728GHz	–	5.85GHz

Communication	Distance	(unobstructed)	–	FCC	Compliance:	800m

Receiver	Sensitivity	(1%PER)	- -93dBm

Transmitter	Power	–	FCC	Compliance:	100mW

Working	Voltage	–	120mA@3.7V

Range	Extender

Operating	Frequency	–	2412-2462MHz

1.1.5.2	Communication	Distance	(unobstructed)	– 500-700m-1.1.5.3	

Transmitter Power	–	20dBm

Power	Consumption	–	2W

APPENDIX	–	B

DJI	INSPIRE	1	TECHNICAL	SPECIFICATIONS

Marsha	E.	Copeland	d.b.a	Overlook	Aerials	will	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	well	as	limit	flight	to	a	predetermined	
35

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)

Aircraft

Name:	Inspire	1

Model	–	T600

Weight	(Battery	Included)	–	6lbs	7.5291oz	(2935g)

3	Hovering	Accuracy	(GPS	Mode)	–	Vertical:	0.5m;	Horizontal:	2.5m

Max	Angular	Velocity	– Pitch:	3000/s;	Yaw:	1500/s	2.2.1.5	Max	Tilt	

Angle-	350

Max	Ascent	Speed	–	5m/s

Max	Descent	Speed	–	4m/s

Max	Speed	–	22m/s	(ATTI	mode,	no	wind	–	NOT

RECOMMENDED)

Max	Flight	Altitude	–	4500m

Max	Wind	Resistance	–	10m/s

Max	Flight	Time	–	Approximately	18	minutes

Motor	Model	–	DJI	3510

Propeller	Model	–	DJI	1345

Operating	Temperature	Range	–	140F	to	1040F	(-100C	to	400C)

Dimensions	–	17	1⁄4”	x	17	3⁄4”	x	12”

Gimbal

Model:	ZENMUSE	X3

Output	Power	(with	camera)	–	Static:	9W;	In	Motion:	11W	2.2.2.3

Operating	Current	–	Static:	750mA;	In	Motion:	900mA	2.2.2.4	Angular	

Vibration

Range	-	±0.030

Mounting	–	Detachable

Controllable	Range	–	Pitch:	-900	to	+300;	Pan:	±3200	2.2.2.7	Mechanical

Range	–	Pitch:	-1250	to	450;	Pan:	±3300	2.2.2.8	Max	Controllable	Speed	

–	Pitch:	1200/s;	Pan:	1800/s

Camera

Name:	X3

Model	–	FC350

Total	Pixels	–	12.76M

Effective	Pixels	–	12.4M

Image	Max	Size	–	4000x3000

ISO	Range	–	100-3200
36

Field	of	View	-	940

CMOS	–	Sony	EXMOR	1/2.3”

HD	Video	Recording	– UHD	(4K):	4096x2160p24/25,

3840x2160p24/25/30;	FHD:	1920x1080p24/25/30/48/50/60;

HD:	1280x720p24/25/30/48/50/60

Operating	Temperature	Range	-	320F	-	1040F	(00C	-	400C)

Transmitter

Name	–	C1

Operating	Frequency	–	5.728-5.850GHz;	2.400-2.483GHz	2.2.4.3

Communicating	Distance	(unobstructed)	–	2000m	2.2.4.4	Output	Power	

–	9W

Operating	Temperature	Range	-	140F	to	1040F	(-100C	to

400C)

Battery	–	600mAh	LiPo	2S

APPENDIX		-	C

YUNEEC	TYPHOON	G500	4K

Marsha	E.	Copeland	d.b.a	Overlook	Aerials	will	only	utilizes	safe	and	

reliable	UASs.	YUNEEC	is	an	industry	leader	in small	UAS	production.	

YUNEEC’S	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	well	as	limit	flight	to	a	predetermined	

and	set distance.	In	addition,	YUNEEC’S	software	provides	real-time	

altitude	and	location information	to	the	PIC	via	the	linked	monitor	ST-10.

Aircraft:

Name:	Typhoon	G500	4K

Weight -	1700g	(per	manual) including	camera

Max	Rotation Rate 65	degrees/s

Max	Roll	Rate	35	degrees

Max	Ascent	Speed	2	m/s

Max	Descent	Speed 3	m/s

Max	Flight	Speed meters/sec

Max	Altitude 400	Ft	AGL	by	default	

Max	Wind	Resistance	8-12	MPH

Max	Flight	Time	-20-25	min
37

Propeller	Main	Rotor	Diameter 13.0	in	(330mm)

Dimensions	9.45	in	(210mm)	x16.54	in	(420	mm)

Gimbal	Camera

Name:	CGO3

Dimension: 	4.2x5.0x3.1	in	(106x128x80mm)

Weight: 	6.9	oz

Operating	Temperature	Range	0-40	degree	C

Effective	Pixels12.4	Megapixels

Resolution-	16	megapixels

FOV:	115	Degree

UHD	Video	Recording 	4K	30FPS

Transmission 	5.2GHz	-	5.8GHz

Transmitter

Name:	ST10+

Operating	Frequency	-	10	channel	2.4	GHz	with	5.8	GHz	video	link

RC	Modulation:	Yuneec

Telemetry/OSD:	YES

SD	Card	Compatible:	YES

LCD	Screen	Size:	5.5"	Touch

Operating	Frequency 	5.8	GHz

Communication	Distance	(unobstructed) 	600	m	(1970	ft)

Power	Consumption	10W

Operating	Temperature	Range:	NA

Battery	5400mAh	3S	11.1V	LiPo