Drew Link

1905 Boulder Street Saint Peter, MN 56082

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

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act:

14 CFR Part 21, Subpart H

14 C.F.R. § 45.23 (b)

14 C.F.R. § 61.113 (a) and (b)

14 C.F.R. § 91.7(a)

14 C.F.R. § 91.9 (b) (2)

14 C.F.R. § 91.103

14 C.F.R. § 91.109

14 C.F.R. § 91.119

14 C.F.R. § 91.121

14 C.F.R. § 91.145(b)

14 C.F.R. § 91.151(a)

14 C.F.R. § 91.203 (a) and (b)

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

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012. I, Drew Link, operator of an Unmanned Aircraft System (UAS), Cheerson CX-20, hereby applies for an exemption from the listed Federal Aviation Regulations to allow commercial operation of its UAS, so long as such operations are conducted within and under conditions outlined herein or as may be established by the FAA as required by Section 333.Commercial operation of an UAS, as described herein, which are equipped with a camera and sensors,

would operate in the following manner:

• Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering, and other related professional activities. • Aerial video and/or photography for public and/or private use including television, public/sporting events, and news gathering. • Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority. • Aerial video/photography of natural disasters happening in Minnesota. • Aerial video/photography or providing live video feed to assist with the search and rescue operations in life threatening emergencies or natural disaster only when the local authorities or government has requested it by contract or donation. • The ability to offer training to persons individually or belonging to both private and/or public organizations that have interests in the use and application of a UAS for the purpose of the safe operation of a UAS to enhance the safety of National Airspace System as well as the protection of the persons and property.

As described fully below, the requested exemption would permit the operation of a UAS under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's responsibilities to "establish requirements for the safe operation of such aircraft systems in the national airspace system.

Drew Link Aerial Photography will operate the Cheerson CX-20 Professional, Model CXHOBBY CX-20, with a total weight of 1,279g or 2.81bs. The dimensions are 295mm x 295mm x 105mm/ 11.61inch x 11.61inch x 4.13 inch. The maximum speed under still air is no more that 22m/s or 49 mph. The CX-20 has the ability to hover and move on its vertical and horizontal planes simultaneously. The CX-20 has four motors, powered by a 6-cell 2700mAh Lithium Polymer battery. It has four propellers. The four blades are Cheerson CX-20 Self-tightening Blades. The CX-20 will be controlled with the factory radio controller with an operating frequency of 2.4GHz. The live video feed will use a operating frequency of 5.645MHz — 5.945 MHz;8 ch. The applicant will operate the UAS in line of sight within a closed off or predetermined area owned and operated by the property representative.

The name and address of the applicant is: Drew Link Aerial Photography
1905 Boulder Street Saint Peter. MN 56082 Ph(507)340-4117 Email: drew.link2340@gmail.com14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 Ibs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements. The FAA will have advance notice of all operations. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words'9imited," "restricted," "light-sport," "experimental," or "provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word "ExperimentaP" can be placed. Given the size of the UAS, two-inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification of the UAS as "Experimental:'14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in

Command.

Pursuant to 14 CFR 61.113 (a) &(b), no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire. Drew Link Aerial Photography may achieve an equivalent level of safety as achieved by current Regulations because the applicant's UAS do not carry any pilots or passengers nor property.

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety check lists prior to each flight an equivalent level of safety will be provided. Prop locks have been issued for this aircraft so the possibility of a prop flying off mid flight is inevitable which also achieves a higher safety factor.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides: No person may operate a U.S: registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the UAS will have immediate access to it.

14 C.F.R. § 91.103: Preflight Action. This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. Before the aircraft takes flight, a home GPS location will be set for any reason the aircraft becomes disoriented in flight, and return safely to home.

14 C.F.R. §91.109: Flight Instruction.

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, by their design do not have fully functional dualcontrols. Flight control is accomplished through the use of a control box that communicates with the

aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft.

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

Section 91.119 establishes safe altitudes 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. As this exemption is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent. It also may be operated over open water close to shore keeping a distance of 500 feet as indicated in Section 91.119 (c). The equivalent level of safety wilf be achieved given the size, weight, and speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 551bs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently with conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations of the UAS will ensure separation between these UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings.

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "...to the elevation of the departure airport or an appropriate altimeter setting available before departure." As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the Iaunch site shown on the GPS altitude indicator before flight. The DJI Inspire 1 uses DJI Vision Positioning. It is a positioning system that uses ultrasonic and image data to help the aircraft identify its current position. With the help of Vision Positioning, the Inspire 1 can hover in place more precisely and fly indoors or in other environments where there is no GPS signal available. The main components of DJI Vision Positioning are located on the bottom which includes two sonar sensors and one monocular camera. This provides a significant level of safety.14 C.F.R §91.145(b) Management of aircraft operations in the vicinity of aerial

demonstrations and major sporting events

CFR 91.145 states: (b) In deciding whether a temporary flight restriction is necessary for an aerial demonstration or major sporting event not listed in paragraph (a) of this section, the FAA considers the following factors: (1) Area where the event will be held. (2) Effect flight restrictions will have on known aircraft operations. (3) Any existing ATC airspace traffic management restrictions. (4) Estimated duration of the event. (5) Degree of public interest. (6) Number of spectators. (7) Provisions for spectator safety. (8) Number and types of participating aircraft. (9) Use of mixed high and low performance aircraft. (10) Impact on non-participating aircraft. (11) Weather minimums. (12) Emergency procedures that will be in effect.

If Drew Link Aerial Photography intends to use the UAS to cover sporting events from outside the activity, coordination will be completed by contacting the FSDO prior to the event to ascertain the presence of any other unmanned activities. Flight activity will be conducted based on safety and with particular attention to the avoidance of overflight of large concentrations of people. However, specific relief from this regulation is still necessary to ensure compliance with
FARs.

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 an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed -(1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes:' The battery powering the UAS provides approximately 15 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 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 twilight VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the 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 speed of the small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the exemption will begranted. Applicant believes that an equivalent level of safety can be achieved by limiting

flights to 20 minutes or 30% of battery power— whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate.. .. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs no more than 55 Ibs. and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS.

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 in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...," and others shall inspect or maintain the aircraft in compliance with Part 43. Given that this section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent Ievel of safety will be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period oftime. If inechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. 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. Most importantly, 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. An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operator will ensure that the UAS is in working order priorto initiating flight and perForm required maintenance needed.

Add ition al I nformation The applicant, Drew Link, has been involved in the building and the piloting of remote controlled aircraft for more than 7 years. The applicant has logged over 1000 hours on a flight simulator, flying fixed wing aircraft; therefore the applicant is knowledgeable of FAA procedures and rules. Also the primary pilot, Drew Link, has an in-depth understanding of the capabilities and safetyconcerns involved in using this technology as an asset to the community. The technology can be used in

such a way that it benefits the community as a whole and can educate future pilots in a safe environment. The satisfaction of criteria provided in Section 333 of the Reform Act of 2012 provides a level of safety that should be satisfactory to the FAA and general public. The applicant believes this exemption would benefit the public by providing a professional service for the public. The applicant would not exercise the exemption outside the United States. The applicant would also requests the FAA NOT to impose a condition that the PIC must hold either an airline transport,commercial, private, recreational, or sport certificate. The applicant requests this because he does not possess any of the certifications and obtaining one would be too costly and outside the scope of the intended goal of Link Aerial Photography. As described above the applicant has basic aviation knowledge. In view of the beneficial advantages to public safety, I respectfully submit my Section 333 exemption request for allowing the commercial operation of the applicant's UAS.

Sincerely,



# ~

. Drew Link