February 16, 2016

FAA Docket Management Facility U.S. Department of Transportation 1200 New Jersey Avenue, SE West Building, Ground Floor, Room W12

- 140 Washington, DC 20590
Dear Exemption Manager,
I am submitting my Petition for Exemption for Unmanned Aircraft Systems (UAS) operations. I am a licensed Light Sport Pilot, certificate numbers 3191624, and I hold a Repairman Light Sport Aircraft, also shown on my license. I have over 700 hours in Exper imental Light Sport Powered Parachutes and have been flying since 2004. I understand the importance of operating a UAS in a safe manner.
My request is for a waiver of the sections ident ified below in an effort to operate a UAS for commercial photography a nd video. Operating a UAS would offer our potential customers a unique view point for their photos and video.
My request is to operate a UAS for commercial purposes to record aerial videos and photography of real estate, general photography, and special events.
I am seeking exemption of: Section of 14CFR: parts 21 Subpart H, 27, 45.23 (b), 45.27 (a), 6 1.113 (a) and (b) , 61.133 (a), 9 1.7 (a), 91.9 (b) (2), 91.103, 91.109 (a), 91.119, 91.121, 91.151 (a), 91.203 (a) and (b), 91.319 (a) (1), 91.405 (a) (1), 91.409 (a) (2), 91.417 (a)” and (b). If I have erroneously omitted any other relevant section or, overstated any relevant section for my intended operations, please feel free to suggest the missing or overstated section(s).

Suggested Public Federal Reg ister Summary: “The petitioner is seeking an exemption to operate an unmanned aircraft system (UAS) under the new FAA “Summary Grant” approach, announced April 9 th, 2015 http://www.faa.gov/news/ updates/?newstd=82485 that will help speed up Section 333 exemption approvals for many commercial UAS operators prior to finalizing the small UAS proposed rules published this past February. It is my understanding that the FAA will still revieweach Sectio n 333 petition individually. However, it is my hope that you find that the enhanced

safety achieved using an unmanned aircraft with the specifications described by the petitioner which carries no passengers or crew, rather than a manned aircraft of signifi cantly greater proportions, carry crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enable by this exemption is in the public interest. I am hoping that the agency will accept my particular petition, and include it in the next summary grant, and issue me an exemption on the presumption that the FAA has “already granted a previous exemption similar to this request”.
Apparently, the new interim policy includes the granting of a Certificate of Waiver or Authorization (COA) for fights at or below 200 feet to any UAS operator with a Section 333 exemption for aircraft that weight is less than 55 pounds, operate during daytime Visual Flight Rules (VFR) conditions, operate within visual line of sight (VLOS) of the pilots, a nd stay certain distances away from airports or heliports such as 5 nautical miles (NM) from an airport having an operational control tower; or 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or 2 NM from an airport without a published instrument flight procedure or an operational tower; or 2 NM from a heliport with a published instrument flight procedure. It is also understood that the “blanket” 200 foot COA allows flights anywhere in the county except restr icted airspace and other areas, such as major cities, where the FAA prohibits UAS operations.

UAS Description: I am asking for an exemption for a UAS up to 55 pounds because I forecast I will be using a craft that will be flown operationally, weighting less than five pounds and more specifically the DJI Phantom models as well as the Yuneec Q300 model, and will be qualified as a UAS.

In the event a loss of communications occurs the craft will rise up vertically to a safe height before beginning an automa ti c return to home function. The control signal may be reconnected in flight and the pilot can take over safe operations again if communication is reestablished. However in the case of a GPS failure the craft will be able to be manually flown to a safe lan ding by the pilot. The craft operates electrically, carries no flammable fuel, and has an inte grated GPS pilot system. I understand the importance of condu cting safe flight operations and planning flight paths which minimize flights over crowds. Flights wi ll end when battery reserve reaches no less than 25 percent. Operations will not occur under IFR conditions. In addition, preflight and post flight checklists and UAS examinations will help detect any abnormalitiesprior to flight and after flight. Any UAS unable to satisfy safety checklist will be removed from

service until the issue can be resolved.
Granting this request would not adversely affect safety since operations would be in accordance with current UAS rules.
Section 333 Compliance and Appropria t e ness: Based on the size of the craft, experience of the pilot, and operational goals, this request appears to be well suited for approval using the current cr iteria outlined in Section 333 of the FAA Modernization and Reform Act of 2012 (including new in terim policies).
Sincerely submitted,

Robert P. Coffman 3207 State Route 746 Cardington, Ohio 43315 (614)313

- 2746 Email: rcoffman135@hotmail.com