Jonathan B. Hill

T: +1 202 776 2725 jhill@cooley.com

1299 PENNSYLVANIA AVENUE, NW, SUITE 700, WASHI NGTON, DC 20004

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U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Summary Processing: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 61.113(a) & (b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417 (a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Re form Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Chapman Aerospa ce LLC (“Chapman”) operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to conduct commercial flights for aerial photography and filming (hereinafter “the Purpose”), hereby a pplies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA in an exe mption granted under either Sect ion 333 or 49 U.S.C. § 44701(f) . Chapman will accept the conditions set forth in Exemptions Nos. 11062 and its progeny Nos. 11063, 11064, 11065, 11066, 11067, 11080, 11150 and 11158 (“the Similar Exemptions). We ask for su mmary approval of this exemption request

.

As this Exemption request is identical to the seven already granted, and uses the same aircraft approved in exemptions 11063; 11065; 11067, this Exemption should qualify for summary processing as the FAA has alread y given public notice of and granted similar exemptions

. 1 As with the approval of the Similar Exemptions, approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “ ...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.

The name and address of the applicant is:

Chapman Aerospace LLC

Attn: Justin Chapman

243 Molino Ave Long Beach

, CA 90803

Ph: (805)390

- 5723

1 Chapman will be using two aircraft: DJI S

- 1000+ and the DJI S900.February 3, 2 015 Page Two

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- 7899 WWW.COOLEY.COM Regulations from which the exemption is requested:

14 C.F.R. 61.113(a) & (b)

14 C.F.R. 91.119

14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.405(a) 14 C.F.R. 407(a)(1) 14 C.F.R. 409(a)(2) 14 C.F.R. 417(a) & (b)

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS or the public or p ose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the op erator.

Reform Act § 333(a). Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” I d. § 333(c) (emphasis added) 2

.

The Federal Aviation Act, in addition to the authority granted by Section 333 of Reform Act, expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft , as the term is defined under § 40101 of the Act, that includes sUASs, from the requirement that all civil aircraft must have a current airworthiness

certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed

under subsection (a) or (b) of this section or any sections 44702

- 44716 of the Transportation Act if the Administrator finds the exemption in the public interest. 49 U.S.C. § 44701(f). See

also 49 U.S.C. § 44711(a); 49 U.S.C. § 44704; 14 C.F.R. § 91.203(a)(1)

.

Chapman is a startup company that will enter the movie and television, aerial photography for television and film industry. Chapman UASs are rotorcraft, weighting 55 or fewer lbs. including payload. They operate, under normal conditions at a speed of n o more than 50 knots and have the capability to hover, and move in the vertical and horizontal plane

2 Applicant interprets this provision to place the duty on the Admi nistrator to not only process applications for exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the UAS, if it should be determined that the conditions set forth herein do not fulfill the statutory requi rements for approval.February 3, 2015 Page Three

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- 7899 WWW.COOLEY.COM simultaneously. They will operate at altitudes of no more than 400 feet, as further explained, and only in line of sight. They will operate only within t he sterile areas as described in the Chapman Flight Operations Manual (“FOM”) Exhibit 1. In addition to the FOM attached are Chapman Pilot Operating Handbooks (“POH”) for the DJI S1000+ (Exhibit 2), the POH for the DJI S900 (Exhibit 3), the Chapman DJI Ma intenance Manual and Instructions for Continued Airworthiness for the FJI S1000+ (“MM”) (Exhibit 4), and DJI S900 Maintenance Manuals and Instructions for Continued Airworthiness (“MM”), (Exhibit 5) (hereinafter “the Manuals”) 3

. Operations in compliance with these manuals will insure that the sUAS will “not create a hazard to users of the national airspace system or the public” 4 and that the aircraft will operate in compliance with the conditions set forth in this application.

Given the small size of the sUASs involved and the restricted environment within which they will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to the size of the UASs, the restricted areas in which the relevant sUASs will operate and the fact that aircraft will be flown by pilots holding at least a FAA private pilot license, approval of the application p resents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing battery powered UASs for these functions instead of turbine or gas power aircraft/rotorcraft and operations with pilots hav ing at least a private pilot license, the grant of the requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The a pplicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operati ons under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe movie and television filing operations conducted with conventional aircraft

. 5

These limitations and conditions to which Chapman a grees to be bound when conducting commercial operations under an FAA issued exemption include:

1. The UA must weigh less than 55 pounds, including energy source(s) and equipment. Operations will be limited to the aircraft described in the proprietary Manuals:

3 Applicant submits the Manuals, marked “CONFIDENTIAL”, as they contains propriety business information that is not released to the public and is protected under t he Freedom of Information Act, 5 U.S.C. § 553, etc.

4 Reform Act Sectio n 333(b).

5 These conditions are reproduced from Similar Exemptions (11062 through 11067 , 11080 , 11150 and 11158).February 3, 2015 Page Four

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- 7899 WWW.COOLEY.COM 2. The UA may not be flown at a speed exceeding a ground speed of 50 knots.

3. Flights must be operated at an altitude of no more than 400 feet above ground level (AGL) as indicated by the procedures specified in the Operators Manuals. All altitudes reported to ATC must be in feet AGL.

4. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued medical certificate.

5. All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS requirement, as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times.

6. The operat or will be bound by and follow the Manuals as accepted by the FAA. Any additional requirements identified in the final conditions for this Exemption will be added

to the Manuals. The Manuals will be maintained and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in the final exemption and the procedures outlined in the Manuals, the conditions and limitations of the Exemption will take precedence and will be followed. Otherwise, the operator will follow the procedures as outlined in its Manuals.

The operator will update or revise its Manual. It will be the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon
request. The opera tor will also present updated and revised documents if it petitions for

extension or amendment. If the operator determines that any update or revision would affect the basis for which the FAA granted this exemption, then the operator will petition for

ame ndment to their exemption. The operator will contact the FAA’s UAS Integration Office (AFS

- 80) with questions arising regarding updates or revisions to the Manual.

7. Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe

f light. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft will not operate until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Statio n, if utilized, will be included in the preflight inspection. All maintenance and alterations will be properly documented in the aircraft records.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristic s, e.g. replacement of a flight critical component, must undergo a functional test flight in accordance with the Manual. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. The requirements and pr ocedures for a functional test flight and aircraft record entry must be

added to the Manuals.

9. The operator will follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. When unavailable

, aircraft maintenance/component/overhaul, replacement, and inspection/maintenanceFebruary 3, 2015 Page Five

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- 7899 WWW.COOLEY.COM requirements will be established and identified in the Manuals. At a minimum, the following must be included in the Manual:

a. Actuators / Servos

b. Transmission (single rotor)

c. P owerplant (motors)

d. Propellers

e. Electronic speed controller

f. Batteries

g. Mechanical dynamic components (single rotor)

h. Remote command and control

i. Ground control station (if used) j. Any other components as determined by the operator

10. The PIC will possess at least a private pilot certificate and at least a current third

- class

medical certificate. The PIC will also meet the flight review requirements specified in 14 C.F.R. § 61.56 in an aircraft in which the PIC is rated on his/her pilot certificate.

11. Prior to operati ons conducted for the Purpose, the PIC will have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot and at least ten hours logged as a UAS pilot with a similar UAS type (single blade o r multirotor). Prior documented flight experience that was obtained in compliance with applicable regulations will be used to satisfy this requirement. Training, proficiency, and experience

- building flights may also be conducted under this grant of

exemp tion to accomplish the required flight cycles and flight time. During training, proficiency, and experience

- building flights, all persons not essential for flight operations

will be considered non

- participants, and the PIC will operate the UA with appropr iate

distance from non

- participants in accordance with 14 C.F.R. § 91.119.

12. Prior to operations conducted for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61 .51(b), a minimum of five hours as UAS pilot operating the make and model of UAS to be utilized for operations under the exemption and three take

- offs and three landings in the preceding 90 days. Training, proficiency, experience

- building, and take

off an d landing currency flights can be conducted under this grant of exemption to accomplish the required flight time and 90 day currency. During training, proficiency, experience

- building, and take

- off and landing currency flights all persons not essential

fo r 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.

13. Prior to any flight operations authorized by this grant of exemption, the PIC and VO m ust have successfully completed a qualification process, as outlined in the operator’s

manual. As this is a requirement stipulated by the operator, the test must be developed and implemented by a qualified person designated at the sole discretion of the o perator. A record of completion of this qualification process must be documented and made available to the Administrator upon request.February 3, 2015 Page Six

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- 7899 WWW.COOLEY.COM 14. Prior to operations conducted for the Purpose, a flight demonstration, administered by
an operator

- approved and

- qualif ied pilot will be successfully completed and

documented. This documentation will be available for review upon request by the

Administrator. Because the knowledge and airmanship test qualifications will be developed by the operator, and there are no estab lished practical test standards that support a jurisdictional FAA Flight Standards District Office (FSDO) evaluation and approval of company designated examiners, the Operator will conduct these tests in

accordance with the Manual.

15. The UA will not be opera ted directly over any person, except authorized and consenting personnel necessary for the Purpose, below an altitude that is hazardous to persons or property on the surface in the event of a UAS failure or emergency.

16. Regarding the distance from participat ing persons, the Manual establishes safety mitigations for authorized and consenting personnel. At all times, those persons must be essential to the Purpose. Because these procedures are specific to participating persons, no further FSDO or aviation safe ty inspector approval is necessary for reductions to the distances specified in the petitioner’s manuals. This is consistent with the manned aircraft procedures described in FAA Order 8900.1, V3, C8, S1 Issue a

Certificate of Waiver for Motion Picture and Television Filming.

17. Regarding distance from non

- participating persons, the operator will ensure that no persons are allowed within 500 feet of the area except those consenting to be involved and necessary for the Purpose. This provision may be reduced to no less than 200 feet if it would not adversely affect safety and the Administrator has approved it. For example, an equivalent level of safety may be determined by an aviation safety inspector’s evaluation of the filming production area to note terrain features, obstructions, buildings, safety barriers, etc. Such barriers may protect nonparticipating persons (observers, the public, news media, etc.) from debris in the event of an

accident. This is also consistent with th e same FAA Order 8900.1, V3, C8, S1.

18. If the UAS loses communications or loses its Global Positioning System (GPS) signal, the UA will be programmed to return to a pre

- determined location within the security perimeter and land or be recovered in accordance with the Manual.

19. The UAS will abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the Manual.

20. Each UAS operation will be completed within 30 minutes flight time or with 25% battery power remaining, whichever occurs firs t.

21. The operator will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under an exemption. The operator will request a Notice to Airman (NOTAM) not more than 72 hours in advance

, but not less than 48 hours prior to the operation.February 3, 2015 Page Seven

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- 7899 WWW.COOLEY.COM 22. All aircraft operated in accordance with this exemption will be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

- Number) markings in accordance wi th 14 C.F.R. part 45, subpart C. Markings will be as large as practicable.

23. The operator will develop procedures to document and maintain a record of the UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul
component parts , and the total time in service of the UAS. These procedures will be

added to the Manual.

24. Each UAS operated under this exemption will comply with all manufacturer Safety

Bulletins.

25. The operator will develop UAS technician qualification criteria. These cr iteria will be

added to the Manual.

26. The preflight inspection section in the Manual will be amended to include the following requirement: The preflight inspection will account for all discrepancies, i.e. inoperable components, items, or equipment, not cove red in the relevant preflight inspection

sections of the Manual.

27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA will comply with the Federal Communications Commission (FCC) or other appropriate governmen t oversight agency requirements.

28. At least three days before scheduled filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local FSDO with jurisdiction over the area of proposed filming. The 3

- day not ification may be waived with the

concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS filming production conducted under this grant of exe mption;

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

- scene operation of the UAS;

d. Make, model, and serial or N

- number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the filming production

event;

f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request;February 3, 2015 Page Eight

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- 7899 WWW.COOLEY.COM g. Signature of exemption

- holder or representat ive; and

h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

29. The documents required under 14 C.F.R. § § 91.9 and 91.203 will be available to the PIC at the ground control station of the UAS any time the aircraft is operating. These documents will be made available to the Administrator or any law enforcement official
upon request.

30. The UA will remain clear and yield the right of way to all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.).

31. UAS operations will not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations will be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) will not be undertaken.

32. The UAS will not be operated by the PIC from any moving device or vehi cle.

33. The UA will 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.

34. The UA will not operate in Class B, C, or D airspace without written approval from the

FAA. The UA will not operate within 5 nautical miles of the geographic center of a non

towered airport 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 will be made available to the Administrator upon
request.

35. Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the Federal Aviation Administration’s (FAA) UAS Integration Office (AFS

- 8 0) within 24

hours. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov . Further flight operations will not be conducted until the incident, accident, or transgression is reviewed by AFS

- 80 and authorization to resume operations is provided.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 C.F.R. including, but not limited to, parts
45, 47, 61, and 91.February 3, 2015 Page Nine

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- 7899 WWW.COOLEY.COM 14 C.F.R. § 61.113(a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.

Sections 61.113(a) & (b) limit private pilots to non

- commercial operations. Because the

UAS will not c arry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s license rather than a commercial pilot’s license to operate this smal l UAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the Manual. The level of safety provided by the requirements included in the Manual exceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. § 61.113(a) & (b). The FAA has granted exemptions for private pilots to conduct similar operations in Exemptions 11062, 11063, 11064, 11065, 11066, 11067 and 11080.

14 C.F.R. § 91.119: Minimum Safe Altitudes.

Section 91.119 establishes safe a ltitudes for operation of civil aircraft. Section 91.119(d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the

FAA. A s this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL an exemption may be needed to allow such operations. As set forth herein, except for the limited conditions stated in the Manual and in condition #3, page 3, the UAS will never operate at higher than 400 AGL.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. No flight will be taken without the p ermission of the property owner, facility owner and local officials. Because of the advance notice to the property owner and participants all affected individuals will be aware of the planned flight operations as set forth in the Manual. Compared to flig ht operations with aircraft or rotorcraft weighting far more than the maximum 55 lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL in the aerial photography industry. In addition, the low

altitude operations of the sUAS will ensure separation between these small

- UAS operations and the operations of conventional aircraft that must comply with Section 91.119. The F AA has granted exemptions to conduct similar operations in Exemptions 11062, 11063, 11064, 11065, 11066, 11067 and 11080.

14 C.F.R. § 91.121: Altimeter Settings.

This regulation requires each person operating an aircraft to maintain cruising altitude by

re ference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the sUAS in at least one operating mode will not have a barometric altimeter, but instead a GPS altitude re ad out, an exemption will be needed. An equivalent level of safety will be achieved by the operator, pursuant to the ManualFebruary 3, 2015 Page Ten

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- 7899 WWW.COOLEY.COM and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. The FAA has g ranted exemptions to conduct similar operations in Exemptions 11062, 11063, 11064, 11065, 11066, 11067 and 11080.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions.

Section 91.151(a) prohibits an individual from beginning “a flight in a n airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

– (1) During the day, to fly after that for at least 30 minute s; or (2) At night, to fly after that for at least 45

minutes.”

The battery powering the sUAS provides approximately 40 minutes of powered flight. To meet the 30 minute reserve requirement in 14 C.F.R. § 91.151, sUAS flights would be limited to approxim ately 10 minutes in length. Given the limitations on the UAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable.

Applicant believ es that an exemption from 14 C.F.R. § 91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151(a)). Operating the small UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and s peed of the small UAS.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery power whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 10808 and Exemptions 11062, 11063, 11064, 11065, 11066, 11067 and 11080.

14 C.F.R. § 91.405(a); 407 (a)(1); 409(a)(2); 417(a) & (b): Maintenance Inspections.

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided i n paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an air worthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook as referenced in the Flight Operations and Procedures Manual (FOPM) attached as c onfidential Exhibit 2. (See) An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in areas for limited periods of time. If

mechanical issues arise the UAS can lan d immediately and will be operating from no higherFebruary 3, 2015 Page Eleven

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- 7899 WWW.COOLEY.COM than 400 feet AGL. As provided in the FOPM, the operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. The FAA has granted exemptions for similar operations in Exemptions 11062, 11063, 11064, 11065, 11066, 11067 and 11080.

*********

Pursuant to 14 C.F.R. part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed:

Applicant seeks an exemption from the follo wing rules:

14 C.F.R. §§ 61.113(a) & (b); 91.7(a); 91.119; 91.121; 91.151(a); 91.405(a); 91.407(a) (1); 91.409(a)(2); 91.409(a)(2) and 91.417(a) & (b) to operate commercially a small unmanned vehicle (55 lbs. or less) in motion picture and television opera tions.

Approval of exemptions allowing commercial operations of sUASs for filming for motion picture and television work will enhance safety by reducing risk. Conventional operations, using jet or piston power aircraft, operate at extremely low altitudes just feet from the subject being filmed and in extreme proximity to people and structures; and present the risks associated with vehicles that weigh in the neighborhood of 6,000 lbs., carrying large amounts of jet A or other fuel (140 gallons for jet heli copters). Such aircraft must fly to and from the project location. In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The s UAS is carried to the target area and not flown. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operation of small UASs, weighting less than 55 lbs., conducted in th e strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein. These lightweight aircraft operate at slow speeds, close to the ground, and in areas that are under the control of the customer for the inspections and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people or the use of people to climb the structures to conduct the inspection.

PRI VACY

All flights will occur over private or controlled access property with the property owner’s prior consent and knowledge. Inspection be of inanimate objects in areas where the owners and/or operator will have consented to observation/ filming or otherwise have agreed to be in the area where inspection will take place.Februa ry 3, 2015 Page Twelve

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- 2400 T: (202) 842

- 7800 F: (202) 842

- 7899 WWW.COOLEY.COM Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

-- size, weight, speed, operating capabilities, proximity to airports and populated areas and operation

w ithin visual line of sight and national security

– provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant’s UAS for the Purposes outlined herein and are consistent with exemptions alrea dy granted, including the Similar Exemptions (11062, 11063, 11064, 11065, 11066, 11067, 11080, 11150 and 11158).

Sincerely,

Jonathan B. Hill Cooley LLC Counsel for Chapman Aerospace, LLC

John McGraw John McGraw Aerospace Consulting, LLC Agent for Chap man Aerospace, LLC

cc: James Williams Robert Pappas

Jake Troutman Dean Griffith, Esq. Thuy H. Cooper Justin Chapman

113113170

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