### U NITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION 800 INDEPENDENCE AVE, SW WASHINGTON, DC 20591

Regulatory

Docket No. FAA

- 2007

- 0001

**IN THE MATTER OF THE PETITION OF:**  

## Stephen M. Cobaugh **FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS 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**  **A DJI INSPIRE 1**  **UNMANNED AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF**  **THE FAA MODERNIZATION AND REFORM ACT OF 2012**

**PUBLIC LAW 112**
**- 95** 

Submitted on December 3 0 , 2015 Stephen M. Cobaugh 231 School L

N Elizabethtown, PA 17022

- 8111 Tel: (717) 367

- 51962 **TABLE OF CONTENTS**

GLOSSARY OF ABBREVIATIONS.................................

... ......... ....................... .3 SUMMARY..........................................................................................

....... . .4 IN TRODUCTION AND INTERESTS OF P ETITIONER.......................................

... .. .4 BACKGROUND........................................................................

. ... ... ......... ..... .5 BASI S FOR P ETIT ION.....................................................................

............ ....5 NAME AND ADDRESS OF PETITIONER.......................................

... ..... ...7 THE SPECI FI C SECTI ONS OF 14 C .F.R. FROM WHI CH Stephen M. Cobaugh SEEKS EXEMPTION...................................................

. .................... ..... 7 THE EXTENT OF RELIEF Stephen M. Cobaugh SEEKS AND THE REASON Stephen M. Cobaugh SEEKS THE RELIEF.............................................

. ... 1 1 THE REASONS WHY GRANTI NG Stephen M. Cobaugh’s REQUEST WOUL D BE IN THE PUBLIC INTEREST...........................................................

... 1 4 THE REASONS WHY G RANTI NG THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY..........................................

.. ...... ...... ....1 7 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...

...... 3 1 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT Stephen M. Cobaugh’s REQUEST...........................

.. ...... ...... 3 1 CONCL USION..................................................................

......... . .......... .......3 2 APPENDI CE...........................................................................

. .......... ..........3 43 **G LOSSARY 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 FA R Federal Aviation Regulation GCS Ground Control System GPS Global Positioning System L OL Loss of Link NAS National Airspace System NOTAM Notice to Airman PI C Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line of Sight VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing4 **SUMMARY** Stephen M. Cobaugh 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 o perate an Unmanned Aircraft S ys tem pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Stephen M. Cobaugh to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and p hotograph y of construction sites, real estate, landscape, special events, news gathering, and production venues over certain areas of the United States of America.

**INTRODUCTION AND INTERESTS OF THE PETITIONER**  Stephen M. Cobaugh provides his clients with expertise and knowledge in news gathering, photograph y, videography, motion picture production and audio

- visual techniques to increase efficiency , productivit y and effectiveness. Stephe n M. Cobaugh has over 25 y ears of professional experience in photography , videography and news gathering and is a recognized as an expert in these industries , holding two university occupation

- related degrees. He has over 2 y ears recreational/hobby expe rience in all aspects of aerial video and photography . The objective of Stephen M. Cobaugh’s aerial video and photography operations is to provide high quality imaging for a variety

of commercial, public and residential uses, specificall y targeting:

 News gathering operations

 Motion picture filming

 Aerial acquisitions used for inspections of public and private structures.

 In crease public knowledge of UAS and promoting UAS operations.

 Search and Rescue operations

**BACKGROUND** Unmanned Aircraft Sy s tems DJI I nspire 1 UAS5

Stephen M. Cobaugh seeks an exemption to operate a DJ I sy stem for compensation or hire within the NAS. The DJI I nspire 1 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Sy stem (GCS) utilizing electronic tablet or smartphone

s ys tems. The DJ I Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately

42 knots. The DJ I In spire 1 UA is equipped with four main rotors, driven by Lithium Poly

mer battery

powered electric motors. The DJ I Inspire 1 UA that will be operated by Stephen M. Cobaugh will be registered in Accordance with 49 U.S.C. 44103, Registration of A ircraft, 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 Marking. **BASIS FOR PETITION** Petitioner, Stephen M. Cobaugh, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereb y petit ions the Administrator to commercially operate the DJ I Inspire 1 UAS in the National Airspace Sy stem (NAS) and for an exemption from the requirements of 14 C.F.R. §§ 61.113(a) & (b), 91.7(a), 91.151(b), 91.405(a), 91.407(a)(1), 91.409 (a)(1) & (a)(2), a nd 91.417(a) & (b). In consideration of the speed, weight, size and limited operating area associated with the Unmanned aircraft and its operations, Stephen M. Cobaugh’s operation of a DJI I nspire 1 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. Accordingl y, Stephen M. Cobaugh requests relief from Sections 91.405(a), 91.407(a)(1),6

91.409(a)(1) & (a)(2), and 91.417(a) & (b ), as these sections set forth requirements for maintenance that onl y apply to aircraft with an airworthiness certificate. Stephen M. Cobaugh submits that the requested relief is proper since an equivalent level of safet y will be ensured. Stephen M. Cobaugh will use experienced personnel or technicians to perform maintenance, alterations, or preventative maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Lo g, and DJI I nspire 1 Instruction Manual). Furthermore, Stephen M. Cobaugh will document and maintain all maintenance records for the DJ I Inspire 1 UAS. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot Privil eges and limitations: Pilot in command, is requested b y Stephen M. Cobaugh to the extent necessary

to allow necessary

to allow a Pilot in Command (PI C) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, b y meeting minimum flight

- hour and currency requirements, that the PI C is able to safel y operate the DJI I nspire 1 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate d istances from people, vessels, vehicles and structures. Stephen M. Cobaugh seeks relief from Section 91.7(a), entitled Civil aircraft Airworthiness, because the DJ I Inspire 1 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Stephen M. Cobaugh submits that he will ensure that the DJ I Inspire 1 UAS are in an airworth y condition, prior to every flight, b y determining that the UAS is in compliance with the operating documents (i.e ., Monthly Maintenance Log, and DJ I Inspire 1 Instruction Manual), and that the aircraft is in a condition for safe flight. Stephen M. Cobaugh also seeks an exemption from the requirements of Section 91.121,7

entitled Altimeter Settings, as the DJ I Inspire 1 UA will not have a t ypical barometric altimeter onboard. However, altitude information of the DJ I Inspire 1 UA will be provided to the PI C via Global Positioning Sy stem (GPS) equipment and radio communications telemetry data link, whi ch downlinks from the UA to the GCS for active monitoring of the flight path. The altitude information, combined with Stephen M. Cobaugh’s operation of the DJI I nspire 1 UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safet y equivalent to Section 91.121. Additionally , Stephen M. Cobaugh seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Stephen M. Cobaugh submits that safety will not be af

fected by operation of the DJ I In spire 1 UA during d ay light hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery

power to fl y for a duration of approximately 13.5 minutes to the first point of intended lan ding and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 11.81, Stephen M. Cobaugh provides the following In formation in support for exemption: **A. Name and A**  **ddress of the Petitioner.** The name and address of the Petitioner and point of contact is: Stephen M. Cobaugh 231 School L

N Elizabethtown, PA 17022

- 8111 Tel: (717) 367

- 5196 Email: smcobaugh@embarqmail.com **B. The Specific Sections of 14 C.F.R. from which Stephen M. Cobaugh seeks Exemption.**  **1. Stephen M. Cobaugh seeks exemptions from the requirements of Section**  **61.113 (a) and (b).**8

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 (PI C) of an aircraft that is carry ing passengers or propert y 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 c onnection with an y business of employment if

— (1) The flight is only

incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property

for compensation or hire. **2. Stephen M. Cobaugh 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 airworth y condition. **3. Stephen M. Cobaugh seeks exemption from the requirements of Secti**  **on 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 fli ght l evel 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 in paragraph (a)(1)(i) of This section, the current reported altimeter setting of an approximate a vailable station; or (iii) I n case of an aircraft not equipped with a radio, the elevation of the d eparture airport or an approximate altimeter setting available before departure.9

**4. Stephen M. Cobaugh seeks exemption from the requirements of Section 91.151(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 (cons idering 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. Stephe n M. Cobaugh seeks 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 prescribe d in Part 43 of this chapter. **6. Stephen M. Cobaugh seeks exemption from the requirements of Section 91.407(a)(1).**  Section 91.407, 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 maintenance, preventive Maintenance, rebuilding, or alteration unless

— (1) It has been approved for return to service b y a person authorized under § 43.7 of this chapter. **7. Stephen M. Cobaugh seeks exemption from the requirements of Sections 91.409(a)(1) and 91.409(a)(2).**  Section 91.409, entitled Inspections, subsection (a), states the 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 pe rson authorized by

§ 43.7 of this chapter; or10 (2) An inspection for the issuance of an airworthiness certificate in accordance With part 21 of this chapter. **8. Step**  **hen M. Cobaugh seeks 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) Exc ept 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) Rec ords of the maintenance, preventive maintenance, and alteration 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 the completion of the work performed; and (iii) T he 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 st atus of life

- limited parts of each airframe, engine, propeller, Rotor, and appliance. (iii) T he time since last overhaul of all items installed on the aircraft which are requir ed to be overhauled on a specified time basis. (iv) The current inspection status of aircraft, including the time since the last i nspection required b y the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safet y directives including, for each, the method of compliance, the AD or safet y directive number and revision date. If the AD or safet y directive involves recurring action, the time and date when the next action is required.11 (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currentl y installed engines, rotors, propellers, and appliances. (b) The owner or opera tor shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 y ear 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 under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for ret urn to service.
**C. The extent of relief Stephen M. Cobaugh seeks and the reason Stephen M. Cobaugh s**  **eeks the relief. 1. Extent of relief Stephen M. Cobaugh seeks and the reason Stephen M. Cobaugh**  **Seeks relief from Sectio n 61.113(a) and (b).**  Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC 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 is Section 61.113(a) and (b) state that a private pilot may , for compensation or hire, act as PI C of an aircraft in connection with an y business or emplo ym ent if: (1) The flight is only incidental to that business or employ

ment: and (2) The aircraft does not carry passengers or propert y for compensation or hire. As set forth more fully

below, Stephen M. Cobaugh submits that an equivalent Level of safet y will be maintained because no PIC will be allowed to operate the DJI I nspire 112

UAS unless that PI C has met certain flight

- hour and currency requirements, demonstrating that the PI C is able to safely operate the DJ I Inspire 1 UAS 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, vehicles and structures. Further, Stephen M. Cobaugh submits that all flights of the DJ I Inspire 1 UAS, conducted b y the PIC pursuant to the grant of this Petition: (1) will be incidental to Stephen M. Cobaugh’s business; and (2) will not carry passengers or property for

c ompensation or hire. **2. Extent of relief Stephen M. Cobaugh seeks and the reason Stephen M. Cobaugh seeks re**  **lief from**  **Section 91.7(a).** Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow Stephen M. Cobaugh to determine that the DJ I In spire 1 UAS is in airworth y condition prior to every fligh t by ensuring that the UAS is in compliance with the operating documents (i.e., the Stephen M. Cobaugh Aerial Operations Manual, Monthly Maintenance Lo g, and DJI I nspire 1 Instruction Manual). Stephen M. Cobaugh seeks the requested relief because the DJ I Inspire 1 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Stephen M. Cobaugh will ensure that the DJ I Inspire 1 UAS is in an airworth y condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Lo g and DJI Inspire 1 Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below. **3. Extent of relief Stephen M. Cobaugh seeks and the reason Stephen M. Cobaugh Seeks relief from Section 91.121.** 13

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI I nsp ire 1 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), St ephen M. Cobaugh seeks the requested relief because the DJ I Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local b arometric pressure or field altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 C.F.R. 91.121 is sought to the extent necessary to comply

with the applicable conditions and limitations stated below. As more full y set forth herein, an equivalent lev el of safet y will be maintained since the DJ I Inspire 1 UA is equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC w ith altitude information of the UA on the heads

- up display

of the GCS. **4. Extent of relief Stephen M. Cobaugh seeks and the reason Stephen M. Cobaugh Seeks**  **relief from Section 91.151(b).** Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flight of the DJ I Inspire 1 UA during day light hours in visual meteorological conditions (VMC), under a visual flight rule s (VFR), for a duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. Stephen M. Cobaugh seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery

powered DJ I Inspire 1 UA will severel y constrain the practicality of any aerial video or still photo flight operations that Stephen M. Cobaugh proposes to conduct14

pursuant to this Petition. Significantl y, as set forth below, the technical specifications of the DJI I nspire 1 UAS, the DJ I Inspire 1 operating documents, and Stephen M. Cobaugh’s proposed operating limitations, ensure that Stephen M. Cobaugh will safel y operate the battery p owered DJ I Inspire 1 during day light 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 crui sing speed, to fl y after that for at least 4.5 minutes. **5. Extent of relief Stephen M. Cobaugh seeks and the reason Stephen M. Cobaugh 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 appl y to aircraft with an airworthiness certificate, Stephen M. Cobaugh requests relief from these Sections because the DJ I Inspire 1 UAS does not require an airworthiness certificate. As set forth more full y below, the DJ I Inspire 1 UAS meets the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingl y, Stephen M. Cobaugh will use trai ned technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Stephen M. Cobaugh Aerial Operations Manual, Monthly Maintenance Lo g, and DJ I Inspire 1 Instruction Manual). Furthermore, Stephen M. Cobaugh will document and maintain all maintenance records for the DJI Inspire 1 UAS.
**D. The reasons why granting Stephen M. Cobaugh’s request would be in the public interest;**  **that is, how it would benefit the public as a whole.**  Granting the present Petition will further the public interest b y allowing Stephen M.15

Cobaugh to safel y, efficiently , and economically perform aerial video and photography of real estate, construction sites, special events, news venues, and landscape over certain areas of the United States of America. Additionally , use of the DJ I Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefi ts to the econom y. Notabl y, Stephen M. Cobaugh’s proposed operation of the DJ I Inspire 1 UAS will be realized without impacting an y privacy

issues. **1. The public will benefit from decreased congestion of the NAS.** The DJ I Inspire 1 UAS is battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery . By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowi ng the use of a DJ I Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safet y of life and property in the air and on the ground. Furthermore, b y reducing the number of manned aircraft operations in the NAS, congestion around airports caused b y arriving and departing aircraft will be reduced. The DJI I nspire 1 UA does not require an airport to takeoff or land. Li kewise, a reduction of manned aircraft conducting aerial video and photograph y missions would result in fewer aircraft that must be handled 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 Inspire 1 UAS.** Conducting aerial acquisitions with the DJI I nspire 1 UAS, instead of manned aircraft will greatly

benefit the public by

drasticall y reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By

using16

battery power and electric motors, the DJ I Inspire 1 UAS produces no air pollution, and is the most viable environmentally conscious alte rnative to the cabin class, six cy linder internal combustion engine aircraft that are t ypically utilized for aerial video and photograph y, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJ I Inspire 1 UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UA is propelled by battery powered electric motors, rather than an internal combustion engine. By using the DJ I Inspire 1 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 operations, will be substantially reduced or completel y eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJ I Inspire 1 UA (weighing approximately 6 pounds 7.5. ounces at its maximum gross weight with a length of 17.3 inches and width of 17.7 inches, and with no fuel on board), has less phy sical potential for collateral damage to l ife and propert y on the ground, and in the air, compared to the manned aircraft that ty pically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). **3. Performing aerial video and photography operations with the DJI Inspire 1 UAS will benefit the economy.**  In addition to being safe and efficient, the DJI I nspire 1 UAS is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJ I Inspire 1 UAS will allow United States based companies like Stephen M. Cobaugh, to remain competitive and contribute to growth of the U.S. economy

. Specificall y, with the cost of aviation fuel and the Environmental Protection Agency (EPA)17

Regulatory

actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating t he battery powered DJ I Inspire 1 UAS is one such technology that not only

allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of traditional manned aircraft. By operating the DJI I nspire 1 UAS, companies such as Stephen M. Cobaugh, can remain competitive and profitable, and therefore, provide greater job stability to emplo ye es and contractors , which ultimately contribute to growth of the U.S. econom y. Im proved financial performance of U.S. companies, through commercial use of the DJI Inspire 1 UAS, provides a stable workforce that increases consumer spending; improves local, state and federal tax revenues; and allows companies to invest in research a nd development in order to remain competitive both in the United States of America and abroad. **4. There are no privacy issues.** Similar to the manned aerial acquisition flight operations that have been conducted for decades, Stephen M. Cobaugh’s proposed operation of the DJ I Inspire 1 UAS will not implicate any

privacy issues. Specificall y, the DJ I I nspire 1 UAS will be operated onl y in compliance with operating documents (i.e., the Stephen M. Cobaugh Aerial Operati ons Manual, Monthly Maintenance Log, and DJ I Inspire 1 Instruction Manual) which requires propert y owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude r equirements of 14 C.P.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 Stephen M. Cobaugh seeks exemption.**  **1. Reasons why the DJI Inspire 1 UA meets the conditions of T**  **he FAA Modernization and Reform Act of 2012 (FMRA) Section 333.** 18

In consideration of the size, wei ght, speed, and limited operating area associated with the UA and its operation, Stephen M. Cobaugh’s operation of the DJ I Inspire 1 UAS 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 airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise p ose a threat to national securit y. Specificall y, 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 ) Assessment of Unmanned Aircraft Systems

— In making the determination under Subsection (a), the Secretary shall determine, at a minimum

— (1 ) whi ch types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operate within visual line of sight do not create a ha zard to users of the national airspace system or the public or pose a threat to national security; and (2 ) whether a certificate of waiver, certificate of authorization, or airworthiness certificati on 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 Operations

— If the Secretary determines under this se ction 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 s ystem.

In seeking this exemption, Stephen M. Cobaugh submits that the DJ I In spire 1 UAS can operate safel y in the NAS pursuant to FMRA Section 333, as demonstrated by : (a) the characteristics of the DJ I Inspire 1 UAS; (b) the pilot certification requirement; and (c) the19

specific operating limitations. **a. The specifications of the DJI Inspire 1 UAS demonstrate its safe characteristics.** The DJ I Inspire 1 UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national securit y considering its size, weight, speed, and operational capability

. **(i) Technical specifications of the DJI Inspire 1 UAS.** The technical specifications of the DJ I Inspire 1 UAS are set forth by the DJ I Inspire 1 Specifications and Data Sheet, attached hereto as Exhibit A. **(ii) The DJI Inspire 1 UAS autonomous flight and navigation modes unable the UAS to remain within a defined operational area**  **.** The DJ I Inspire 1 UAS may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI I nspire 1 UAS is provided at pages 12

- 16 and 45

- 50 of the DJ I In spire 1 User Manua l, attached hereto as Exhibit B. **(iii) The DJI Inspire 1 UAS are designed for automatic return to home point or hover in the event of loss of the control link or navigation.**  When the Control Link is lost, the DJ I Inspire 1 UA will remain stationary , in flight, for 3 seconds or more. If, after 3 seconds, the DJ I Inspire 1 does not reacquire control link data from the GCS, the UA will assume that the Control L ink is lost and the UA 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 DJ I Inspire 1 GCS and flight control software is provided at pages 40

- 47 of the DJI I nspire 1 User M anual. The DJ I User Manual is attached hereto as Exhibit C.20

**(iv) The DJI Inspire 1 GCS and its operation.** A complete description of the operation and specifications of the DJI Inspire 1 GCS and flight control software is provided on pages 40

- 47 of the DJ I Inspire 1 User Manual. The DJ I Inspire 1 User Manual is attached hereto as Exhibit C. **b. Flight operations of the DJI Inspire 1 UAS are limited to the line of sight of a certified Pilot in Comman**  **d with a safety observer.** Stephen M. Cobaugh will only utilize certified pilots who possess a current and Valid airman medical certificate to act as a pilot in command (PI C) of the DJI I nspire 1 UAS. Additionally , a safety observer will assist all pilots during flight time. **c. Flights of the DJI Inspire 1 UAS**  **will be conducted pursuant to specific operating limitations.**  In seeking this exemption, Stephen M. Cobaugh proposes to commercially operate the DJI Inspire 1 UAS for the special purpose of conducting aerial video and photograph y over certain areas of the United States, pursuant to the following specific operating limitations; 1. Operations authorized by this grant of exemption will be limi ted to the following aircraft described in the operating documents, a rotorcraft UAS weighing less than 55 pounds maximum gross weight: DJ I Inspire 1 UAS. Proposed operations of an y other aircraft will require a ne w 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 UA may

not be flown at an indicated airspeed exceeding 20 knots. 4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated b y the procedures specified in the opera ting documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 5. The UA must be operated within visual line of sight (VLOS) of the PI C at all times. This requires the PI C to be able to use human vision unaided by any device other than corrective lenses, as specified on the PI C’s FAA

- issued airman medical certificate.21

6. The use of first person view (FPV) b y the PI C or safet y observer (SO) is not permitted. 7. All operations must utilize a safet y observer (SO). The SO may be used to satisfy The VLOS requirement as long as the PIC alway s maintains VLOS capabil ity . The SO and PI C must be able to communicate verball y 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 operating documents. 8. The SO must not perform an y other duties bey ond 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 instr uments. 9. 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 limitati ons contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, t he operator must follow the procedures as outlined in its operating documents. The operator may

update or revise its operating documents. I t is the operator’s responsibility to track such revisions and present updated and revise d documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. I f 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 Integration Office (AFS

- 80) may be contacted if questions arise regrading updates or revisions to the operating documents. 10. 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 condition that af fects 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 Statio n must be included in the preflight inspection. All maintenance and alterations must be properl y documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records. 12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not alread y covered in the relevant sections of the operating documents.22

13. The operat or must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping req uirements, 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. 15. Each UAS operated under this exemption must comply with all manufacturer Safet y Bulletins. 16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. The PI C must possess at least the minimum FAA required pilot certif icate and the minimum medical certificate necessary to comply

with the provisions of the requested Section 333 exemption. 18. The operator may

not permit any

PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safel y operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency

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 operato r’s PI Cs 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 essen tial for flight operations are considered non

- participants, and the PI C must operate the UA with appropriate distance from non

- participants in accordance with 14 C.F.R. § 91.119. 19. UAS operations may not be conducted d

uring night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to pr oposed area of operations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA may

not operate 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 required b y the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request. 21. The UA may

not be operated less than 500 feet below or less than 2,000 feet h orizontally

from a cloud or when visibility is less than 3 statute miles from the PI C.23

2 2 . If the UA loses communications of loses its GPS signal, it must return to a pre

- determined location within the planned operating area and land or be recovered in accordance with the operating documents. 23. The PI C must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 24. The PI C is prohibited from beginning a flight unless (considering wind and forecast weat her conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting an y operations 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. 26 . 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. 27. 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. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PI C at the Ground Control Station of the UAS any time the UAS is opera ting. These documents must be made available to the Administrator or any law enforcement official upon request. 29. The UA must remain clear and yi eld right of way to all manned aviation operations and activities at a ll times. 30. The UAS may

not be operated by

the PI C from any

moving device or vehicle. 31. Flight operations must be conducted at least 500 feet from all non

- participating persons (persons other than the PI C, SO, operator trainees o r essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect non
- participating persons from the UA and/or debris in the event of an ac cident. The operator must ensure that non

- participating persons remain under such protection. If a situation arises where non

- participating persons leave such protection and are24 with in 500 feet of the UA, flight operations must cease immediatel y and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/ controller of such vessels, vehicles or structures has granted permission and the PI C has made a safet y 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 PI C, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 32. All operations shall b e conducted over private or controlled

- access propert y with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported the FAA’s UAS Integra tion 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

. **2. Reasons why an exemption from the requireme nts of Section 61.113(a) and (b)**  **would not adversely affect safety.** Stephen M. Cobaugh submits that the equivalent level of safet y established by Section 61.113(a) and (b) will be maintained because no PI C will be allowed to operate the DJI I nspire 1 UAS unless the PI C has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PI C is able to safely operate the DJ I 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. Considering Stephen M. Cobaugh’s proposed area of operations, and the operating limitations set forth above; the parallel nature of private pilot ae ronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safel y operate the DJ I Inspire 1 UAS, Stephen M. Cobaugh submits that the additional manned airmanship experien ce of a commercially25

certified pilot would not correlate to the airmanship skills necessary for Stephen M. Cobaugh’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 presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). Stephen M. Cobaugh will not allow an y P IC to operate the DJ I Inspire 1 UAS unless that PI C has demonstrated, by meeting minimum flight

- hour requirements or DJ I Inspire 1 UAS training and currency requirements, that the PI C is able to safely ope rate the DJ I Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and
structures. Specificall y, the PIC must 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 (with a minimum of 5 h ours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exempti on). I n addition to the hour requirements, the PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety

during Stephen M. Cobaugh’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 follows: 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 a ccumulated and logged, in a manner consistent with 14 C.F.R. 61.51(b), 25 hours of26

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 P IC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make 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 time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In additi on to the hour requirements, the PI C must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate t o 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 regulatio ns 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 experience

- building flights the PI C is required to operate the UA with appropriate distances in accordance with 14 C.F.R. 91.119. Exemption No. 11138 at page 15. Accordingl y, Stephen M. Cobaugh will ensure safe operations by not allowing an y P IC to operate the DJ I Inspire 1 UAS unless that PI C has demonstrated, by meeting minimum flight

- hour and currency

requirements, that the PIC is able to safel y operate the DJ I Inspire 1 UAS in a manner consistent with the exemption, including evasi ve 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 not adversely affect safety.**  The equivalent level of safet y established by Section 91.7(a) will b e maintained because prior to every

flight, Stephen M. Cobaugh will ensure that the DJ I In spire 1 UAS is in an airworth y condition based upon the UAS’s compliance with its operating docu ments and as stated in the conditions and limitations herein. Additionally , the FAA has previousl y granted relief from Section 91.7(a) specific t o27

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). **4. Reasons why an exemption from the requirements of Section 91.121 would not adversely affect safety.**  The equivalent level of safet y established by Section 91.121 will be maintained b ecause the altitude information of the DJ I Inspire 1 UAS will be provided to the PI C via GPS equipment and a radio communication tele metry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Stephen M. Cobaugh’s operation of the DJ I Inspire 1 UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safet y equivalent to Section 91.121. The altitude information will be generated b y GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically

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, 11157, 11158, 11159, 11160, 11161).
**5. Reason why an exemption from the requirements of Section 91.151(b) would not be adversely affect safety.**  A grant of this exemption would ensure an equivalent level of safet y established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJ I Inspire 1 UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed f

light operations. Accordingl y, Stephen M. Cobaugh will ensure that he will safel y28

operate the battery

powered DJ I Inspire 1 UA during day light hours in VFR conditions, with enough battery

power to fl y for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the DJI I nspire 1 UAS; the limitations on the proposed flight operati ons; and the location of the proposed operations, will ensure an equivalent level of safety established b y 14 C.F.R. Section 91.151(b). Furthermore, safet y will be ensured as the DJ I Inspire 1 UAS provide audible and visual warnings to the PI C at the GC S when the UA experiences low battery voltage, the first warning occurring at approximately 33% remaining battery

power, and again at approximately

10% remaining battery

power. At the criticall y low battery level, the DJI I nspire 1 UAS will descend and land automatically

. Significantl y, previous exemptions granted by the FAA concerning Section 91.151 establish that safet y is not adversel y 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, including 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 herein (e.g., Exemption Nos. 8811, 10808, 10673, 11042, 11062, 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.**29

In seeking this exemption, Stephen M. Cobau gh submits that the equivalent level of safet y with regard to the regulatory maintenance and alteration requirements 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 Stephen M. Cobaugh will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., the Stephen M. Cobaugh Aerial Operations Manual, Monthly Maintenance Log, and DJI I nspire 1 Instruction Manual). Furthermore, Stephen M. Cobaugh will document and maintain all maintenance records for the DJ I Inspire 1 UAS. Since the DJ I Inspire 1 UAS will be inspected as prescribed b y the operating documents, Stephen M. Cobaugh will maintain the equivalent level of safety established b y Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A cop y of the DJ I Inspire User Manual is attached hereto as Exhibit C; a copy of the DJ I Inspire 1 UAS Maintena nce Manual is attached hereto as Exhibit D. Li kewise, the exemption sought will not adversel y affect safet y because Stephen M. Cobaugh will use train ed technicians to perform maintenance, alterations or preventative maintenance on the UAS us ing the methods, techniques, and practices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safet y established by

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI I nspire 1 UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantl y, previous exemptions granted by the FAA concerning Sections 91.405(a),30

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversel y affected when the technical characteristics and operating limitations of the UAS are considered. In consideration of Stephen M. Cobaugh’s proposed operating limitations, the operating documents, and the technical aspects of the DJ I Inspire 1 UAS, Stephen M. Cobaugh submits that safety will not be adversel y affected b y granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a )(1) and (a)(2), 9 1.409(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, 110067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **7. The FAA may prescribe any other conditions for safe operations.** In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) a nd 14 C.F.R. § 21.16 entitled Special Conditions, Stephen M. Cobaugh requests that the FAA prescribe special conditions for the intended operation of the DJI I nspire 1 UAS, which contain safety standards that the Administrator finds necessary to establis h a level of safety

equivalent 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), and 91.417(a) & (b). Such special conditions will permit sa fe operation of the UA for the limited purpose of conducting aerial video and photograph y over certain areas of the United States of America 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 public, or otherwise pose a threat to national security ; and further, provides the31

authority for such UAS to operate without airworthiness certification in accordance with with any requirements that must be established for the safe operation of the UAS in the NAS. Li kewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJ I Inspire 1 UAS, since the airworthiness regulations of 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 t his 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, the FAA prescribes special conditions and amen dments thereto for the product. The 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 lev el of safet y equivalent to that established in the regulations. 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 Stephen M. Cobaugh’s intended operation of the DJ I Inspire 1 UAS, which contain such safet y 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). **F. A Summary that can be published in the Federal Register, stating: The rules from which Stephen M. Cobaugh seeks exemption:**  Stephen M. Cobaugh 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 Stephen M. Cobaugh seeks:**  This exemption will permit Stephen M. Cobaugh to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and Photography over certain areas of the United States

.32

**G. Any additional information, views or arguments available to support Stephen M. Cobaugh’s request.**  This petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UASs may

operate safel y in the NAS. As such, Stephen M. Cobaugh’s 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 securit y; and further, provides the authority for such UAS to operate without airw orthiness certification. As discussed in detail above, Stephen M. Cobaugh will operate the DJI I nspire 1 UAS Safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise p ose a threat to national securit y.
**CONCLUSION** As set forth herein, Stephen M. Cobaugh 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 DJ I Inspire 1 UAS commercially , without an airworthiness certificate, for the purpose of conducting aerial video and photograph y over certain areas of the United States. By

granting this petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Moderniza tion and Reform Act of 2012, while also advancing the interests of the public, by allowing Stephen M. Cobaugh to safel y, efficientl y, and economically

operate the DJ I Inspire 1 UAS commerciall y within in NAS.33

**WHEREFORE** , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Stephen M. Cobaugh respectfull y 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 Stephen M. Cobaugh to operate the DJI I nspire 1 UAS commerciall y for the purpose of conducting aerial video and photograph y over certain a reas of the United States. Dated: December 3 0 , 2015

Respectfully submitted, 

# A b Stephen M. Cobaugh 231 School L

N Elizabethto wn, PA 17022

- 8111 Tel: (717) 367

- 5196

Appendices: A

– DJ I Inspire 1 Specifications Data Sheet B

– DJ I Inspire 1 User Manual

– PDF link: h ttp://dl.djicdn.com/downloads/inspire_1/en/I nspire_1_User_Manual_v1.0_en.pdf C

– DJI I nspire 1 Maintenance Manual

– PDF link: http://dl.djicdn.com/downloads/inspire_1/en/I nspire_1_Maintenance_ManualV1.0_en.pdf34 APPENDIX

– A **DJI INSPIRE 1 TECHNICAL SPECIFICATIONS** Stephen M. Cobaugh onl y utilizes safe and reliable UASs. DJ I is an industry leader in small UAS production. DJI UASs are loaded with ground

- breaking software enabling the user t o 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, DJ I software prov ides real

- time altitude and location information to the PI C via the linked monitor (smartphone/tablet devices). 2.2 DJI Inspire 1 2.2.1 Aircraft 2.2.1.1 Model

– T600 2.2.1.2 Weight (battery included)

– 6 lbs., 7.5291 oz. (2,935g) 2.2.1.3 Hovering accuracy (GPS mode)

– Vertical: .05m; Horizontal: 2.5m 2.2.1.4 Max Angular Velocity

– Pitch: 300°/s; Yaw: 150°/s 2.2 .1.5 Max Tilt Angle

-- 35° 2.2.1.6 Max Ascent Speed

– 5m/s 2.2.1.7 Max Descent Speed

– 4m/s 2.2.1.8 Max Speed

– 22m/s (ATTI Mode, no wind

– NOT RECOMMENDED) 2.2.1.9 Max Flight Altitude

– 4,500m 2.2.1.10 Max Wind Resistance

-- 10m/s 2.2.1.11 Max Flight Time

– Approximately 18 minutes 2.2.1.12 Motor Model

– DJI 3510 2.2.1.13 Propelle r Model

– DJI 1345 2.2.1.14 Operating Temperature Range

-- 14°F to 104°F (

- 14°C to 40° C) 2.2.1.15 Dimensions
– 17

- 1/4” x 17

- 3/4” x 12” 2.2.2 Gimbal 2.2.2.1 Model

– ZENMUSE X3 2.2.2.2 Output Power (with camera)

– Static: 9W; In Motion: 11W 2.2.2.3 Operating Current
– Static: 750mA; In Motion: 900mA 2.2.2.4 Angular Vibration

-- +/

- 0.03° 2.2.2.5 Mounting
– Detachable 2.2.2.6 Controllable Range

– Pitch:

- 90° to +30°; Pan: +/

- 320° 2.2.2.7 Mechanical Range

– Pitch:

- 125° to 45°; Pan: +/

- 330° 2.2.2.8 Max Controllable Speed

– Pitch: 120°/s; Pan: 180°/s
2.2.3 Camera 2.2.3.1 Name
– X3 2.2.3.2 Model

– FC35035 2.2.3.3 Total Pixels

– 12.76M 2.2.3.4 Effective Pixels

– 12.4M 2.2.3.5 Image Max Size
– 4000 x 3000 2.2.3.6 ISO Range
– 100

- 3200 2.2.3.7 Field of View

-- 94° 2.2.3.8 CMOS
– Sony EXMOR 1/2.3” 2.2.3.9 HD Video Recording

– UHD(4K): 4096 x 2160p24/25, 3840 x 2160p24/25/30; FHD: 1920 x 1080p24/25/30/48/50/60; HD: 1280 x 720p24/25/30/48/50/60 2.2. 3 .10 Operating Temperature Range

-- 32°

- 104°F (0° C

- 40°C) 2.2.4 Transmitter 2.2.4.1 Name
– C1 2.2.4.2 Operating Frequency
– 5.728

- 5.850GHz; 2.400

- 2.483GHz 2.2.4.3 Communicating Distance (unobstructed)

– 2,000m 2.2.4.4 Output Power
– 9W 2.2.4.5 Operating Temperature Range

-- 14°F to 104°F (

- 10°C to 40°C) 2.2.4.6 Battery
– 600mAh LiPo 2S