UNITED 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 30, 2015

 Stephen M. Cobaugh

 231 School LN

 Elizabethtown, PA 17022-8111

 Tel: (717) 367-5196
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TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS.....................................................................3

SUMMARY...................................................................................................4

INTRODUCTION AND INTERESTS OF PETITIONER.............................................4

BACKGROUND..............................................................................................5

BASIS FOR PETITION.....................................................................................5

 NAME AND ADDRESS OF PETITIONER..................................................7

 THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH Stephen M. Cobaugh

 SEEKS EXEMPTION.............................................................................7

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

 Stephen M. Cobaugh SEEKS THE RELIEF.................................................11

 THE REASONS WHY GRANTING Stephen M. Cobaugh’s REQUEST WOULD

 BE IN THE PUBLIC INTEREST..............................................................14

 THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

 ADVERSELY AFFECT SAFETY............................................................17

 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.........31

 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE

 TO SUPPORT Stephen M. Cobaugh’s REQUEST.........................................31

CONCLUSION.............................................................................................32

APPENDICE................................................................................................34
3

GLOSSARY 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

FAR Federal Aviation Regulation 

GCS Ground Control System

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

 

NOTAM Notice to Airman

PIC 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 Landing
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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 operate an Unmanned Aircraft System 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 photography 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,

photography, videography, motion picture production and audio-visual techniques to increase

efficiency, productivity and effectiveness. Stephen M. Cobaugh has over 25 years 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 years recreational/hobby experience 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, specifically targeting:

 News gathering operations

 Motion picture filming

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

 Increase public knowledge of UAS and promoting UAS operations.

 Search and Rescue operations 

BACKGROUND

Unmanned Aircraft Systems DJI Inspire 1 UAS
5

 Stephen M. Cobaugh seeks an exemption to operate a DJI system for compensation or

hire within the NAS. The DJI Inspire 1 is a vertical takeoff and landing (VTOL) Unmanned

Aircraft (UA) with a Ground Control System (GCS) utilizing electronic tablet or smartphone

systems. The DJI 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 DJI Inspire 1 UA is equipped with four main rotors, driven by

Lithium Polymer battery powered electric motors.

 The DJI Inspire 1 UA that will be operated by Stephen M. Cobaugh will be registered in

Accordance with 49 U.S.C. 44103, Registration of Aircraft, 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, hereby petitions the

Administrator to commercially operate the DJI Inspire 1 UAS in the National Airspace

System (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), and 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 Inspire 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.

 Accordingly, Stephen M. Cobaugh requests relief from Sections 91.405(a), 91.407(a)(1),
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91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for

maintenance that only apply to aircraft with an airworthiness certificate.

 Stephen M. Cobaugh submits that the requested relief is proper since an equivalent level

of safety 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 Log, and DJI Inspire 1 Instruction Manual). Furthermore, Stephen M. Cobaugh

will document and maintain all maintenance records for the DJI Inspire 1 UAS.

 Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot

Privileges and limitations: Pilot in command, is requested by Stephen M. Cobaugh to the

extent necessary to allow necessary to allow a Pilot in Command (PIC) holding a private

pilot or higher level certificate, as well as an airman medical certificate, and who has

demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is

able to safely operate the DJI 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.

 Stephen M. Cobaugh seeks relief from Section 91.7(a), entitled Civil aircraft

Airworthiness, because the DJI 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 DJI Inspire 1 UAS are in an airworthy condition, prior to every

flight, by determining that the UAS is in compliance with the operating documents (i.e.,

Monthly Maintenance Log, and DJI 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,
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entitled Altimeter Settings, as the DJI Inspire 1 UA will not have a typical barometric

altimeter onboard. However, altitude information of the DJI Inspire 1 UA will be provided

to the PIC via Global Positioning System (GPS) equipment and radio communications

telemetry data link, which 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 Inspire 1 UAS within visual line of sight, at or below 500 feet AGL, will ensure a level

of safety 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 affected by operation of the DJI Inspire 1 UA during

daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR),

with enough battery power to fly for a duration of approximately 13.5 minutes to the first

point of intended landing and, assuming normal cruising speed, to fly after that for at least

4.5 minutes.

 In accordance with 14 C.F.R. § 11.81, Stephen M. Cobaugh provides the following

Information in support for exemption:

A. Name and Address of the Petitioner.

The name and address of the Petitioner and point of contact is:

Stephen M. Cobaugh

231 School LN

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

 (PIC) of an aircraft that is carrying passengers or property 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

 connection with any business of employment if—

 (1) The flight is only incidental to that business or employment; 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 airworthy condition.

 3. Stephen M. Cobaugh seeks exemption from the requirements of Section

 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 flight

 level 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

 available station; or

 (iii) In case of an aircraft not equipped with a radio, the elevation of the

 departure 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

 (considering 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. Stephen 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 prescribed 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 by 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 person authorized by § 43.7 of this

 chapter; or
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 (2) An inspection for the issuance of an airworthiness certificate in accordance

 With part 21 of this chapter.

 8. Stephen 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) Except 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) Records 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) The 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 status of life-limited parts of each airframe, engine, propeller,

 Rotor, and appliance. 

 (iii) The time since last overhaul of all items installed on the aircraft which are

 required to be overhauled on a specified time basis.

 (iv) The current inspection status of aircraft, including the time since the last

 inspection required by the inspection program under which the aircraft and

 its appliances are maintained.

 (v) The current status of applicable airworthiness directives (AD) and safety

 directives including, for each, the method of compliance, the AD or safety

 directive number and revision date. If the AD or safety directive involves

 recurring action, the time and date when the next action is required.
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 (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major

 alteration to the airframe and currently installed engines, rotors, propellers,

 and appliances.

 (b) The owner or operator 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 year 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 return to service.

C. The extent of relief Stephen M. Cobaugh seeks and the reason Stephen M. Cobaugh

 seeks the relief.

 1. Extent of relief Stephen M. Cobaugh seeks and the reason Stephen M. Cobaugh

 Seeks relief from Section 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 PIC of an aircraft in

connection with any business or employment if: (1) The flight is only incidental to that

business or employment: and (2) The aircraft does not carry passengers or property for

compensation or hire.

 As set forth more fully below, Stephen M. Cobaugh submits that an equivalent Level

of safety will be maintained because no PIC will be allowed to operate the DJI Inspire 1
12

UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating

that the PIC is able to safely operate the DJI 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 DJI Inspire 1 UAS, 

conducted by 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

compensation or hire.

 2. Extent of relief Stephen M. Cobaugh seeks and the reason Stephen M. Cobaugh

 seeks relief 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 DJI Inspire 1 UAS is

in airworthy condition prior to every flight by ensuring that the UAS is in compliance with

the operating documents (i.e., the Stephen M. Cobaugh Aerial Operations Manual, Monthly

Maintenance Log, and DJI Inspire 1 Instruction Manual). 

 Stephen M. Cobaugh seeks the requested relief because the DJI 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 DJI Inspire 1 UAS is in an airworthy

condition based upon its compliance with the operating documents (i.e., Monthly

Maintenance Log 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 Inspire 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), Stephen M. Cobaugh seeks the requested relief because the DJI

Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local

barometric 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 fully set forth herein, an equivalent level of safety will be

maintained since the DJI 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 with 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 DJI Inspire 1 UA during daylight

hours in visual meteorological conditions (VMC), under a visual flight rules (VFR), for a

duration of 13.5 minutes to the first point of intended landing and, assuming normal

cruising speed, to fly 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 DJI Inspire 1 UA will severely constrain the practicality of

any aerial video or still photo flight operations that Stephen M. Cobaugh proposes to conduct
14

pursuant to this Petition.

 Significantly, as set forth below, the technical specifications of the DJI Inspire 1 UAS,

the DJI Inspire 1 operating documents, and Stephen M. Cobaugh’s proposed operating

limitations, ensure that Stephen M. Cobaugh will safely operate the battery powered DJI

Inspire 1 during daylight 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 cruising speed, to fly 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 apply to aircraft with an airworthiness certificate, Stephen M. Cobaugh requests relief

from these Sections because the DJI Inspire 1 UAS does not require an airworthiness

certificate. As set forth more fully below, the DJI Inspire 1 UAS meets the conditions of

FMRA Section 333 for operation without an airworthiness certificate. Accordingly,

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 UAS operating documents (i.e., the Stephen M. Cobaugh Aerial Operations Manual,

Monthly Maintenance Log, and DJI 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 by allowing Stephen M.
15

Cobaugh to safely, 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 DJI Inspire 1 UAS will decrease congestion of the NAS,

reduce pollution, and provide significant benefits to the economy. Notably, Stephen M.

Cobaugh’s proposed operation of the DJI Inspire 1 UAS will be realized without

impacting any privacy issues.

 1. The public will benefit from decreased congestion of the NAS.

 The DJI 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 allowing

the use of a DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS,

reduce noise and air pollution, as well as increase the safety of life and property in the air and

on the ground.

 Furthermore, by reducing the number of manned aircraft operations in the NAS,

congestion around airports caused by arriving and departing aircraft will be reduced. The

DJI Inspire 1 UA does not require an airport to takeoff or land. Likewise, a reduction of

manned aircraft conducting aerial video and photography 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 Inspire 1 UAS, instead of manned aircraft

will greatly benefit the public by drastically reducing the levels of air and noise pollution

generated during traditional aerial video and still photography flight operations. By using
16

battery power and electric motors, the DJI Inspire 1 UAS produces no air pollution, and is

the most viable environmentally conscious alternative to the cabin class, six cylinder

internal combustion engine aircraft that are typically utilized for aerial video and

photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel.

The DJI 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 DJI 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 completely eliminated. Aside

from the lack of flight crew members located onboard the aircraft, the DJI 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 physical

potential for collateral damage to life and property on the ground, and in the air, compared

to the manned aircraft that typically 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 Inspire 1 UAS is also an economical

alternative to using manned aircraft to conduct similar aerial operations. As such,

operation of the DJI 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.

Specifically, 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 the

battery powered DJI 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 Inspire 1 UAS, companies such as Stephen M. Cobaugh, can

remain competitive and profitable, and therefore, provide greater job stability to employees

and contractors, which ultimately contribute to growth of the U.S. economy. Improved

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 and 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 DJI Inspire 1 UAS will not

implicate any privacy issues. Specifically, the DJI Inspire 1 UAS will be operated only in

compliance with operating documents (i.e., the Stephen M. Cobaugh Aerial Operations Manual,

Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual) which requires property

owner involvement as well as local law enforcement notification, and in accordance with the

Federal Aviation Regulations, including the minimum altitude requirements 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 The FAA 

 Modernization and Reform Act of 2012 (FMRA) Section 333.
18

 In consideration of the size, weight, speed, and limited operating area associated with

the UA and its operation, Stephen M. Cobaugh’s operation of the DJI 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 pose a threat to national security.

Specifically, 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) which 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 hazard 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

 certification 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 section

 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 system.

 In seeking this exemption, Stephen M. Cobaugh submits that the DJI Inspire 1 UAS can

operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the

characteristics of the DJI Inspire 1 UAS; (b) the pilot certification requirement; and (c) the
19

specific operating limitations.

 a. The specifications of the DJI Inspire 1 UAS demonstrate its safe characteristics.

 The DJI Inspire 1 UAS does not create a hazard to users of the NAS or the public, or

otherwise pose a threat to national security considering its size, weight, speed, and

operational capability.

 (i) Technical specifications of the DJI Inspire 1 UAS.

 The technical specifications of the DJI Inspire 1 UAS are set forth by the DJI 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 DJI 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 Inspire 1 UAS

is provided at pages 12-16 and 45-50 of the DJI Inspire 1 User Manual, 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 DJI Inspire 1 UA will remain stationary, in flight,

for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 does not reacquire control link

data from the GCS, the UA will assume that the Control Link 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 DJI Inspire 1 GCS and flight

control software is provided at pages 40-47 of the DJI Inspire 1 User Manual. The DJI 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 DJI Inspire 1 User Manual.

The DJI 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 Command 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 (PIC) of the DJI Inspire 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 photography over

certain areas of the United States, pursuant to the following specific operating limitations;

 1. Operations authorized by this grant of exemption will be limited to the following

 aircraft described in the operating documents, a rotorcraft UAS weighing less than

 55 pounds maximum gross weight: DJI Inspire 1 UAS. Proposed operations of any

 other aircraft will require a new 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 by the procedures specified in the operating 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 PIC at all times.

 This requires the PIC to be able to use human vision unaided by any device other

 than corrective lenses, as specified on the PIC’s FAA-issued airman medical

 certificate.
21

 6. The use of first person view (FPV) by the PIC or safety observer (SO) is not

 permitted.

 7. All operations must utilize a safety observer (SO). The SO may be used to satisfy

 The VLOS requirement as long as the PIC always maintains VLOS capability. The

 SO and PIC must be able to communicate verbally 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 any other duties beyond 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 instruments. 

 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 limitations 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,

 the operator must follow the procedures as outlined in its operating documents. The

 operator may update or revise its operating documents. It is the operator’s responsibility

 to track such revisions and present updated and revised 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. If 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 affects 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 Station must be included in the preflight inspection. All maintenance and

 alterations must be properly 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 already covered in the relevant sections of the

 operating documents.
22

 13. The operator 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

 requirements, 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

 Safety 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 PIC must possess at least the minimum FAA required pilot certificate 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 safely 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

 operator’s PICs 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 essential for flight

 operations are considered non-participants, and the PIC 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 during 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

 proposed 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 by 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

 horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.
23

 22. 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 PIC must abort the flight in the event of unpredicted obstacles or emergencies in

 accordance with the operating documents.

 24. The PIC is prohibited from beginning a flight unless (considering wind and forecast

 weather 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 any 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 PIC at the Ground Control Station of the UAS any time the UAS is operating.

 These documents must be made available to the Administrator or any law enforcement

 official upon request.

 29. The UA must remain clear and yield right of way to all manned aviation operations and

 activities at all times.

 30. The UAS may not be operated by the PIC 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 PIC, SO, operator trainees or 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 accident. The operator

 must ensure that non-participating persons remain under such protection. If a

 situation arises where non-participating persons leave such protection and are
24

 within 500 feet of the UA, flight operations must cease immediately 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 PIC has made a safety 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 PIC, SO, operator trainees or essential persons do not

 present an undue hazard to those persons per § 91.119(a).

 32. All operations shall be conducted over private or controlled-access property 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 Integration 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 requirements of Section 61.113(a) and (b)

 would not adversely affect safety.

 Stephen M. Cobaugh submits that the equivalent level of safety established by

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the

DJI Inspire 1 UAS unless the PIC has demonstrated, by meeting minimum flight-hour and

currency requirements, that the PIC is able to safely operate the DJI 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 aeronautical knowledge

requirements to those of commercial pilot requirements (See Exemption No. 11062); and

the airmanship skills necessary to safely operate the DJI Inspire 1 UAS, Stephen M.

Cobaugh submits that the additional manned airmanship experience of a commercially
25

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 any PIC to operate the DJI Inspire 1 UAS unless

that PIC has demonstrated, by meeting minimum flight-hour requirements or DJI Inspire 1

UAS training and currency requirements, that the PIC is able to safely operate the DJI

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.

 Specifically, 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

hours of those hours as a UAS pilot operating the same make and model of UAS to be used

for operations under the exemption). In addition to the hour requirements, the PIC must

accomplish 3 takeoffs and landings in the preceding 90 days (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

 accumulated and logged, in a manner consistent with 14 C.F.R. 61.51(b), 25 hours of
26

 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

 PIC 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 addition to the hour requirements, the

 PIC 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 to 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 regulations 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 PIC is required to operate the UA with appropriate distances in

 accordance with 14 C.F.R. 91.119.

Exemption No. 11138 at page 15.

 Accordingly, Stephen M. Cobaugh will ensure safe operations by not allowing any PIC

to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum

flight-hour and currency requirements, that the PIC is able to safely operate the DJI 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.

 3. Reasons why an exemption from the requirements of Section 91.7(a) would not

 adversely affect safety. 

 The equivalent level of safety established by Section 91.7(a) will be maintained

because prior to every flight, Stephen M. Cobaugh will ensure that the DJI Inspire 1 UAS

is in an airworthy condition based upon the UAS’s compliance with its operating documents

and as stated in the conditions and limitations herein.

 Additionally, the FAA has previously granted relief from Section 91.7(a) specific to
27

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 safety established by Section 91.121 will be maintained

because the altitude information of the DJI Inspire 1 UAS will be provided to the PIC via

GPS equipment and a radio communication telemetry 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 DJI Inspire 1 UAS

within visual line of sight, at or below 500 feet AGL, will ensure a level of safety

equivalent to Section 91.121. The altitude information will be generated by 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 safety established by

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Inspire 1

UAS; (2) the limitations on the proposed flight operations; and (3) the location of the

proposed flight operations. Accordingly, Stephen M. Cobaugh will ensure that he will safely
28

operate the battery powered DJI Inspire 1 UA during daylight hours in VFR conditions,

with enough battery power to fly for a total duration of 13.5 minutes to the first point of

intended landing and, assuming normal cruising speed, to fly after that for at least 4.5

minutes.

 Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 1

UAS; the limitations on the proposed flight operations; and the location of the proposed

operations, will ensure an equivalent level of safety established by 14 C.F.R. Section

91.151(b). Furthermore, safety will be ensured as the DJI Inspire 1 UAS provide audible

and visual warnings to the PIC at the GCS 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 critically low battery level, the

DJI Inspire 1 UAS will descend and land automatically.

 Significantly, previous exemptions granted by the FAA concerning Section 91.151

establish that safety is not adversely 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. Cobaugh submits that the equivalent level of

safety 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 Inspire 1 Instruction Manual).

Furthermore, Stephen M. Cobaugh will document and maintain all maintenance records for

the DJI Inspire 1 UAS.

 Since the DJI Inspire 1 UAS will be inspected as prescribed by the operating

documents, Stephen M. Cobaugh will maintain the equivalent level of safety established by

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Inspire User Manual

is attached hereto as Exhibit C; a copy of the DJI Inspire 1 UAS Maintenance Manual is

attached hereto as Exhibit D. 

 Likewise, the exemption sought will not adversely affect safety because Stephen M.

Cobaugh will use trained technicians to perform maintenance, alterations or preventative

maintenance on the UAS using the methods, techniques, and practices prescribed by the

operating documents.

 Furthermore, the exemption sought would maintain an equivalent level of safety

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the

DJI Inspire 1 UAS will be performed by trained technicians. Maintenance will be documented

and maintained utilizing the monthly maintenance log.

 Significantly, 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 adversely

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 DJI Inspire 1 UAS, Stephen M.

Cobaugh submits that safety will not be adversely affected by granting exemption from

14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(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) and 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 Inspire 1

UAS, which contain safety 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.

§§ 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 safe operation of the UA

for the limited purpose of conducting aerial video and photography 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 the
31

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.

 Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. §

21.16, for operation of the DJI 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 this 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 amendments 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 level

 of safety 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 DJI

Inspire 1 UAS, which contain such safety 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 safely 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

security; and further, provides the authority for such UAS to operate without airworthiness

certification.

 As discussed in detail above, Stephen M. Cobaugh will operate the DJI Inspire 1 UAS

Safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise

pose a threat to national security. 

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 DJI Inspire 1 UAS commercially, without an airworthiness

certificate, for the purpose of conducting aerial video and photography over certain areas of

the United States. By granting this petition, the FAA Administrator will be fulfilling the

Congressional mandate of the FAA Modernization and Reform Act of 2012, while also

advancing the interests of the public, by allowing Stephen M. Cobaugh to safely, efficiently,

and economically operate the DJI Inspire 1 UAS commercially 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 respectfully

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 Inspire 1 UAS commercially for the purpose of conducting aerial video and photography

over certain areas of the United States.

Dated: December 30, 2015

 Respectfully submitted,

 Ab

 Stephen M. Cobaugh

 231 School LN

Elizabethtown, PA 17022-8111

Tel: (717) 367-5196

Appendices:

A – DJI Inspire 1 Specifications Data Sheet

B – DJI Inspire 1 User Manual – PDF link:

 http://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.pdf

C – DJI Inspire 1 Maintenance Manual – PDF link:

 http://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_Maintenance_ManualV1.0_en.pdf

 

 

 
34

 

APPENDIX – A

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

 Stephen M. Cobaugh only utilizes safe and reliable UASs. DJI is an industry leader in

small UAS production. DJI UASs are loaded with ground-breaking software enabling the

user to 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, DJI software provides real-time altitude and

location information to the PIC 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 Propeller 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 – FC350
35

 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