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.com 
14 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 dual 
controls. 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 be 
granted. 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 safety 
concerns 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