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 1 5 ,	2015

Marsha	E Copeland d.b.a. Overlook	Aerials

28814	Sopris	Ln San	Antonio,	TX	78260

Marsha@GVTC.com

210	860

- 69042 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 333 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 Ru les

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Tak eoff and Landing4 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 vis ual 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	Ai rcraft	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 t hree models	of	UAS	for	compensation	or	hire	withi n	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)	utili zing	electronic	tablet	or	smart	phone5 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	d riven	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	equippe d	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)	a nd	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,	a nd	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 r equests	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	e xperienced	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

Manua l,	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	Comman d	(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	from7 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	fr om	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 4 00	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 subm its 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	fi rst	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	f or 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.com8 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 O f	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

pr operty	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	in9 parag raph	(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. Ma rsha	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

mainte nance, 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	Se ctions	91.409	(a)	(1)	And	91.409 (a)	(2).

Section	91.409,	entitled Inspections ,	subsection	(a),	states	the10 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

accor dance	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	alterat ion	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)	Th e	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	pro gram	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)	o f	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	un der	§	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

limitation s:	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	or12 hire,	act	as	PIC	of	an	aircraft	in	connection	w ith	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	Aeri als 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,	veh icles	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.	Over look	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	l imitations

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	91.12113 Relief	from	Section	91.121,	entitled	Altimeter	settings,	may	be	required

to	allo w	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	requir es	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	g round	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	91.15 1(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	w ithout	an	exemption from	Section	91.151(b),	the	flight	time duration	of	the	battery	powered	Aircraft w ill 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	the14 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

See k s	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.	Copela n d 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	with out	an airworthiness	certificate. Accordingly, Marsha	E.	Copeland	d.b.a.	Overlook	Aerials will	use	trained

technicians	to perform	maintenance,	alterations,	or	preventive

m aintenance	on	the	UAS using	the meth ods,	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	furthe r	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	implicatin g 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	saf ety	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	c aused	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	handl ed	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.

Co nducting	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	UAS s 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	hou r	of	aviation	fuel.	The	P etitioners’ UASs,	while	reducing	the	carbon	footprint	of	aerial	acquisitions,	also

elimi nate	noise	pollution,	as	the	UAS s 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	ope rations,	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 ha ve less	physical potential	for	collateral	da mage	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	P hotography	Operations	With

UAS Will	Benefit	The	Economy.

In	addition	to	being	safe and	e fficient,	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’ a ircraft	will	allow	United	States	based	companies,	like

Marsha	E.	C opeland	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,	b ut	provides	such	flexibility	without	the	high	operational	cost

of	a	traditional	manned	aircraft. By	operating	UAS such	as	the

p etitioner’s a ircraft,	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	inc reases 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	notification17 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. Copela nd	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	ai rworthiness 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)	Assessme nt	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	cr eate	a	hazard	to	users	of the	national	airspace	system	or	the	public	or	pose	a	threat	to18 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	safel y	in	the	NAS	pursuant	to FMRA	Section	333,	as	demonstrated	by:	(a)	the	charac teristics	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	opera ting

limitations.

a. T he	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	S pecifications	Of	The	DJI	Phantom 3

, the DJI Insp i re	1 UAS ,	and the Y uneec	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	opera ted	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 T he	Event	Of	Loss	Of	The Control	Link Or	Navigation.

When	the	Control	Link	is	lost,	both	the	DJI	Phantom	3	and	DJI Inspire	1	UA S will	remain	stationary,	in	flight,	for	3	seconds	or	more.	If, after	3	seconds,	the	DJI	Phantom	3	and	DJI	Inspire	1	UA S do	not reacquire	control	link	data	from	the	GCS,	the	UA S will	assume	that	the

Control	Link	is	lost	and	the	UA S 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

Manual s	attached	hereto	as	Exhibit	C, D &	E

.

iv.	The	DJI	Phantom	3

, DJ I	Inspire	1 and Yuneec Typhoon Q500	4K GCS	And	Its	Operation

A	complete	description	of	the	operatio n	and	specifications	of	the	DJI

P hantom	3 and	DJI	Inspire	1	GCS	and	flight	control	software	is	pr ovided at	pages	23	through	38	of the	DJI	Phantom	3	User Manual

, pages	40

thro ugh	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	a re	attached	hereto	as	Exhibits

C

, D &	E

.20 a .	Fli ght	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	Phan to m	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	document s, rotorcraft	UAS weighing	less than	55	pounds	maximum	gross	weight: DJI	Phantom	3

, DJI	I nspire	1 and Yuneec	Typhoon Q500	4K Unmanned	Aircraft	Systems.	Proposed	opera tions	of	any	other

aircraft	will require	a	new	petition	or	a	petition	to	amend	this	grant. 2.	UAS	operations	under	this	exemption	will	be	limited	to	conducting operations for	the	purpose	of	aerial	video	and	photography.

3.	The	UAS may	not	be	flown	at	an indicated	airspeed	exceeding	20 k.

4 .	The	UA S must	be	operated	at	an	altitude	of	no	more	than 4 00	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	UA S 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	le nses,	as	specified	on

the	PIC FAA

- issued	airman medical	cer tificate.

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	maintains21 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	operat ing	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	outlin ed	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	re vise	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

extensio n	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 Integra tion	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	condit ion	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	prefl ight	inspection.	All maintenance	and	alterations	must	be	properly	documented	in	the

aircraft	records.

1 0 .	Any	UAS	that	has	undergone	maintenance	or	alterations	that	affect the	UAS	operation	or	flight	characteristics,	e.g.	replacement	of	a	flight

critical	c omponent,	must	undergo	a	functional	test	flight.	The	PIC	who22 conducts	the	functional	test	flight	must	make	an	entry	in	the	aircraft

records.

1 1 .	The	pre

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

1 2 .	The	operator	must	follow	the	UAS	manufacturer’s aircraft/component, maintenance,	overhaul,	replacement,	inspection, and	life	limit	requirements.

1 3 .	The	operator	must	ca rry	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.

1 4 .	Each	UAS operated	under	this	exemption	must	comply	with	all manufacturer	Safety	Bulletins.

1 5 .	The	authorized	person	must make	an	entry	in	the	aircraft	record	of

the corrective	action	taken	against	discrepancies	discovered	between inspections.

1 6 .	The	PIC	must	possess	at	least	a	private	pilot	certificate	and	at	least	a

current third

- class	medical	certificate.

1 7 .	The	operato r	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	emerge ncy 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	considere d	nonparticipants,	and	the	PIC	must operate	the	UA with	appropriate	distance	from	nonparticipants	in accordance	with	14	C.F.R.	§ 91.119.

1 8 .	UAS	operations	may	not	be	conducted	during	night,	as	defined	in	14 C.F.R.	§ 1.1.	A ll	operations	must	be	conducted	un der	visual meteorological	conditions (VMC).	If	flight	at	night	is	required,	a23 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	ope rate	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	requir ed	by	the	operator’s	COA. The	letter	of	agreement with	the	airport	management	must	be	made	available	to the Administrator	upon	request.

2 0 .	The	UA	may	not	be	operated	less	than	500	feet	below	or	less	than 2,000	feet horizontally	from	a	cloud	or	when	visibi lity	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	pow er	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

op erations	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	U AS	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	time s. 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	prote ction.	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/controlle r	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,	op erator	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

representat ive.		Permission	f rom	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	defi ned	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	establi shed	by	Section 61.113(a)	and	(b)	will	be maintained	because	no	PIC	will	be	allowed	to	operate the	DJI	P hantom	3

, DJI	Inspire	1 ,	and	the Yuneec	Typhoon Q500	4K UAS s u nless	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.

Consid ering 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

ne cessary	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

prese nted	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 I nspire	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	op erate	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	manner26 co nsistent 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

wi ll	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 fol lows:

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	mak e	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	tim e	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	fl ight

- 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	experience

building	flights	can	also	be	conducted	under	the	grant	of	exemption to accomplish	the	required	flight	time.	During	training,	proficiency,	and

exper ience

- 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	flight

hour	and	currency	requirements,	that the	PIC is	able	to	safely	operat e UAS s 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	No t	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 in compliance 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	circumstanc es	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	F rom	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 UA S s	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	UA S s	within	visual	line	of sight,	at	or	below 4 00	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	altitud e	initiation	point	is28 autom atically	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	p roposed	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	UA S s	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

Phanto m 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	UA S s	experiences	low	battery	voltage

.

Significantly,	previous	exemptions	granted	by	the	FAA	concerning

Section	91.1 51 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, includ ing 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	herein29 (e.g.	Exemption	Nos. 8811,	10808,	10673,	11042,	110 62,	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 l evel	of	safety	with	regard	to	the	regulatory

maintenance	and	alteration r equirements	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),	an d 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

. T he	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 m aintenance on	the	UAS s using the	methods,	techniques,	and	practices	prescribed by	the	operating

documents.

Furthermore,	the	exemption	sought	would	maintain	an	equivalent	leve l 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 l imitations ,	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	equ ivalent	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	publ ic,	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	of31 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.	Th e 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	regu lations.

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	the32 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 Transp ortation	to	determine	if certain	UAS s 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	Ins p ire	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 t o 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	and33 the	FAA Modernization	and	Reform	Act	o f	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

p hotography 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/s34 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	all ow	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	predetermined35 and	set distance.	In	addition,	DJI	software	provides	real

- time	altitude	and

locatio n information	to	the	PIC	via	the	linked	monitor	(smart phone/tablet	devices)

A ircraft 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	minu tes
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	Curren t

– 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

- 320036 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

- 2 5	min37 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

Transmis s ion 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:	Y ES

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