1 Private and Confidential

Nick Komic ( Coptervate Aerial Imagery, LLC ) Shelby Twp., MI.

- Section 333 Exemption Petition

September 25, 2015

U. S. Department of Transportation Docket Management System

1200 New Jersey Ave,

SE Washington, DC 20590

Re : Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam, I, Nick Komic, ( Coptervate Aerial Imagery, LLC ), am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, Nick Komic, ( Coptervate Aerial Imagery, LLC ) an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, Nick Komic, ( Coptervate Aerial Imagery, LLC ), may operate my small ultra lightweight unm anned aircraft system (“UAS”) in commercially regulated airspace by the Federal Aviation Administration (“FAA”).

Following exemption and approval by the FAA, I, Nick Komic, ( Coptervate Aerial Imagery, LLC ), will primarily use my professionally built DJ I Inspire 1, DJI Phantom 3 and Freely Alta UAS ’s equipped with cameras for the following applications: Closed

- Set Film Operations on Film and Television Productions, as well as aerial videography/cinematography to safely enhance films and commercials; augm entation of real estate listing videos; and the creation of visual and topography layout videos for Search and Rescue (SAR) missions for state and local agency’s, education, agricultural inspections and building and construction zone inspections.2

2 My, Nick Komic, ( Coptervate Aerial Imagery, LLC ) ’s , exemption request would permit the operation of ultra lightweight, unmanned (i.e. piloted by remote control) UAS’s for the development of community and government use videos, permissible within prope rty boundaries for individual homeowners and within in tightly controlled, limited airspaces predetermined in areas away from the general public, airports, heliports and vehicular traffic. Currently, similar lightweight, remote controlled UAS's are lega lly operated by unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe. Furthermore, it is my intent to assist future FAA safety protocols and regulations exclusive to lightweight UAS's for specific video and photogr aphy usage by sharing information with the FAA as I, Nick Komic, ( Coptervate Aerial Imagery, LLC ), record flight data and other pertinent information gained through permitted flight operations.

In addition, granting my, Nick Komic, ( Coptervate Aerial Ima gery, LLC ) ’s , exemption request will comply with the Secretary of Transportation’s (FAA Administrator’s) instructions to not only integrate UAS's into the national airspace system, but to “...establish requirements for the safe operation of such aircraft systems [UAS's] in the national airspace system” under Section 333(c) of the Reform Act specific to the use of UAS's for real estate/Realtor purposes, educational videos, Search and Rescue, land/trusts inspections, agricultural field monitoring,
film/v ideo productions, closed

- set motion picture film operations and television, and structure inspections, to aid state and local agency’s. Further I, Nick Komic, ( Coptervate Aerial Imagery, LLC ), will conduct my operations in compliance with the protocols d escribed herein or as otherwise established by the FAA. For the reasons stated below, I Nick Komic, ( Coptervate Aerial Imagery, LLC ), respectfully request the grant of an exemption allowing me to operate ultra lightweight, remote controlled
UAS’s to aid academic community awareness, to benefit/stimulate attraction to the metro
Detroit area and to enhance personal and public video feed s. A grant that will ultimately allow UAS’s to play a more positive role in our local community by increasing employment opportunities, heightening security measures and decreasing government expenditures by reducing the need for heavier manned aircraft, containing costly, combustible fuel

- a potential public hazard in and of itself.3

3 I. Contact Information:
Nick Komic Coptervate Aerial Imagery, LLC Shelby Township, MI 48317
Phone: 248

- 890

- 2189
Email: nkphotographic@gmail.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Nick Komic, ( Coptervate Aerial Imagery, LLC ) Req uests Exemption are: 14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).

III. The Extent of relief Nick Komic, ( Coptervate Aerial Imagery, LLC ) Seeks and the
Reason He Seeks Such Relief: I, Nick Komic, ( Coptervate Aerial Imagery, LLC ) , submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331

- 334, seeking relief from any currently applicable FARs operating to prevent me, Nick Komic, ( Coptervate Aerial Imagery,
LLC ) , contemplated commercial cinematic, academic and other flight operations within the national airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace system as it is in the public’s interest to do so. My, Nick Komic, ( Coptervate Aerial Imagery, LLC ) ’s, ultra lightweight UAS meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of my ultra ligh t weight UAS is expressly contemplated by the Reform Act. I would like to operate my ultra lightweight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct experience and valuable information for formal regulation that can be administered uniformly to all related UAS aerial video and photography. The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspace system. Co nsiderations include: The weight, size, speed and overall capabilities of the UAS's; Whether the UAS will be operated near airports or heavily populated areas; and, Whether the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a).4

4 Each of t hese items reflect in favor of an exemption for me, Nick Komic, ( Coptervate Aerial Imagery, LLC ) . My UAS’s utilize eight ( 6 ) or less rotating propellers for balance, control and stability. My UAS’s are equipped with the following via video and data teleme try:

1) Altimeter 2) Attitude indicator 3) Ground Speed indicator 4) Magnetic compass 5) Heading indicator 6) Vertical speed indicator 7) Course deviation indicator 8) Radio magnetic indicator 9) GPS location 10) Battery consumption and Battery L eft with approximate time. 11) Loiter and circle mode. 12) Auto safety or RTL ( Return To Launch) 13) Auto landing technology.

Each UAS weighing less than thirty

- five (35) pounds (far below the maximum 55 pound limit); Including camera(s) with or with out gimbal (a camera stabilizer). I, Nick Komic, ( Coptervate Aerial Imagery, LLC ) , considers safety as foremost with each flight. My small unmanned aircraft is designed to hover in place, circle in a specific place or loiter via GPS and can be operated i n winds up to 30.4 knots (35mph) wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 21.7 knots (25 mph). Built in safety systems include a GPS mode that allows my UAS to hover/circle in place or land when radio contr ols
are released.

With three (3) modes to choose from, I will fly with the modes safest to complete the videos for aerial videography/photography and have the ability to choose the safest, most reliable and stable mode to prevent accident and hazard. When pilot communication from the radio control is lost, UAS is designed slowly descend to point of takeoff and or to land at point of launch after ascending to a pre

- set altitude to ensure the UAS will clear any obstacles that may be between the takeof f point and the current position of the UAS. This failsafe altitude will not be set more than 200ft and is determined before each flight.

I, Nick Komic, ( Coptervate Aerial Imagery, LLC ) , will not operate my UAS near airports, hospitals nor police he liports, and do not operate near areas where general public is within fifty to one hundred (50

- 100) yards depending on location, conditions and weather. I am constantly on alert for any manned aircraft (police/medical helicopters, etc.) and prepared to lan d/abort immediately to the nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft may approach near my location. My UAS’s are capable of5

5 vertical and horizontal operations, and is flown only within my lin e of sight, as the remote control pilot. My UAS's are also flown with a second operator who aids in watching for any obstacles, including manned aircraft, within the flight zone of the UAS. Utilizing battery power rather than combustible fuels, flights gen erally last between three (3 ) to fifteen (25) minutes, with an altitude
under on e hundred fifty (150) feet. Three (3 ) Smart Mode s include , position hold, self

- leveling, altitude command, GPS, return home feature, and safety control to return home or land in the event of communication interruption between RC transmitter and UAS.

I, Nick Komic, ( Coptervate Aerial Imagery, LLC ) , utilize a fresh fully charged battery with each flight as a safety precaution; full flight time limit for each battery is eight (8) to thirty (30) minutes as tested. I do not operate my UAS at or below manufacturer recommend minimum charge levels for operation; preferring to remain well within a safe operating range to insure adequate communication between radio control and UAS to eli minate potential for crash, loss of control or hazard. Reserve batteries are at hand with each exercise to insure replacement for sufficient safe level of operation. I do not believe in tak ing risk that may cause a crash that could create hazard to the pub lic/property/manned aircraft, and have no desire to lose an investment. I have clocked numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of this specific UA S's performance under different temperature and weather conditions. I also practice computerized simulated flights to mainta in adequate skills and response/ reflex time. All for the sake of safety.

I, Nick Komic, ( Coptervate Aerial Imagery, LLC ) , am extre mely cautious when operating my UAS/ultra lightweight unmanned aircraft and will not “create a hazard to users of the national airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my
UAS

, it falls well within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the national airspace system. Nick Komic, ( Coptervate Aerial Imagery, LLC ) ’s UAS, used in hobby flight, has a demonstrable safety
record an d does not pose any threat to the general public or national security.

IV. How Nick Komic, ( Coptervate Aerial Imagery, LLC ) ’s Request Will Benefit the Public As A Whole: Aerial videography for geographical awareness, education, search and rescue, land m anagement, structure inspections and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budget companies, average homeowners and property owners the expense of such aerial videography is cost prohibitive. Only large companies and high end Realtors or luxury homeowners can afford to absorb such expense; depriving non

- luxury owners and lower budget companies from a valuable marketing tool. Manned aircraft pose a threat to the public through potential catastrophic crash that the Metro

- Detroit community has experienced in the past with military aircraft, medical helicopters, and news helicopters crashes within the city of Detroit . Each resulting in loss of life.6

6 Each with combustible fuel that exploded and burned on impact. Police helicopters have made emergency hard landings within city limits. My, Nick Komic, ( Coptervate Aerial Imagery,
LLC ) 's, UAS poses no such threat since size and lack of combustible fuel alleviates any potential thr eat to the public. Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's into the national airspace system, hence the passing of the Reform Act. Granting my, Nick Komic, ( Coptervate Aerial Imagery,
LLC ) ’s, exemption request furthers the public interest through academic/visual awareness of the geographical benefits in and around the metro Detroit, Michigan area. My ultra light weight UAS is battery powered and creates no emissions that can harm the envi r onment. The consequence of my ultra light weight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can cause catastrophic devastation to the public. The public’s interest is further ed by minimizing ecological and crash threat by permitting aerial video/photo capture through my battery operated ultra lightweight
UAS's. Permitting me, Nick Komic, ( Coptervate Aerial Imagery, LLC ) , to immediately fly within national air space further s economic growth. Granting my exemption request substantially furthers the economic impact for the metro Detroit, Michigan and surrounding community for companies looking to relocate or build around the Detroit metro area as well as individuals looking to relocate for career advancement through academic and geographical awareness. Both of which serve as a stimulus to the community. V. Reasons Why Nick Komic, ( Coptervate Aerial Imagery, LLC ) ’s Exemption Will Not Adversely Affect Safety Or How The Exempt ion Will Provide a Level of Safety At Least Equal To Existing Rule: My, Nick Komic, ( Coptervate Aerial Imagery, LLC ) ’s, exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting me, Nick Komic, ( Coptervate Aerial Im agery, LLC ) , to log more flight time in FAA controlled airspace, with communication with the FAA, will allow me to contribute to the innovation and implementation of new and novel, as of yet undiscovered safety protocols for Realtors, land and structured

o wners. For development in cooperation with the FAA. In addition I, Nick Komic, ( Coptervate Aerial Imagery, LLC ) , submit the following representations of enhancements to current aerial videography and photography: My DJI Inspire1, DJI Phantom3 UAS’s weigh l ess than seven (7) pounds complete with an integrated ultra

- light weight camera and Freefly Alta UAS for Motion Picture/Film Productions weigh less than thirty

- five (35) pounds complete with a small ultra

- light weight high quality Canon DSLR, Canon C100, C anon C300 and Red Epic camera or similar; I only operate my UAS below 200 feet (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012); My UAS only operate for 3

- 30 minutes per flight; I land my UAS prior to manuf acturer recommended minimum level of battery power; I pilot my UAS through remote control only by line of sight; and have live video feed for a secondary pilot to monitor video recording; I receive a live telemetry feed from my UAS during all flights which include remaining battery voltage, distance, altitude, and any anomalies that may occur during flight;

My UAS’s Command and Control utilizes spread spectrum 2.4Ghz

- 2.485Ghz frequencies in accordance with CFR 47, Part 15 for model aircraft use.

My UAS’s camera system utilizes 5.725Ghz

- 5.875Ghz frequencies in accordance with CFR 47, Part 15.7

7 My UAS’s have a GPS controlled flight controller

- a flight safety feature whereby it hovers or circles and then lands at the GPS takeoff point if communication with the remote control pilot is lost; I actively record and analyze flight data through the DJI Inspire 1 and DJI phantom 3 flight controller app to constantly update and enhance safety protocols; I only operate in reasonably safe environment that are strictl y controlled, are away from power lines, elevated lights, airports and actively populated areas; I conduct extensive preflight inspections and protocol, during which safety carries primary importance; I always obtain all necessary permissions prior to oper ation; and, I have procedures in place to abort flights in the event of safety breaches or potential danger. My, Nick Komic, ( Coptervate Aerial Imagery, LLC ) ’s, safety protocols provide a level of safety equal to or exceeding existing rules. It is importan t to note that absent the integration of commercial UAS into our national airspace system, helicopters are the primary means of aerial video and photography for community awareness real estate, structured inspections, land management and search and rescue. While the safety record of such helicopters is remarkably astounding, there has been local incident involving loss of life as well as extensive property damage; it is far safer to operate a battery powered ultra lightweight UAS. First, the potential loss of life is diminished because UAS's carry no peo ple on board and I only operate my UAS in specific areas away from mass populations. Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatly diminished. Third, the sma ll size and extreme maneuverability of my UAS allow me to remotely pilot away from and avoid hazards quickly and safely. Lastly, given its small size and weight, even when close enough to capture amazing images, my UAS need not be so close to the objects t hey are focused on through the technology and use of post editing software allowing pan and zoom. Accordingly, my UAS has been experimentally operated for familiarization/competency and will continue to operate at and above current safety levels.

VI. A S ummary The FAA May Publish in the Federal Register: 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for

procure ment of necessary airwo rthiness certificates in relation to FAR §91.203(a)(1). The size, weight and enclosed operational area of my, Nick Komic, ( Coptervate Aerial Imagery,
LLC ) ’s, UAS permits exemption from Part 21 because my UAS meets (and exceeds) an equivalent level of safe ty pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My, Nick Komic, ( Coptervate Aerial Imagery, LLC ) ’s, current and project ed UAS's meet or exceed each of
the elements.8

8 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable

.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning systems with a barometric sensor or controlled GPS “geofencing”

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certification s and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by

me, Nick Komic, ( Coptervate Aerial Imagery, LLC )

.

B. 14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. My UAS can be marked with the appropriate “N” number once this “N” number has been given.

C. 14 C.F.R. § 61. 113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non

- commercial operations. I, Nick Komic, ( Coptervate Aerial Imagery, LLC ) , The sUAS Pilot in Command must possess at least a sport pilot certificate and a driver's license. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in which the PIC is rated on his/her pilot certificate as outlined in 14 C.F.R. § 61.

D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greater than 300fclose AGL; safely below
the standard of 400 AGL. I, Nick Komic, ( Coptervate Aerial Imagery, LLC ) , will however operate my UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, w eight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be achieved.

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.1,2,
Manual

The above

- cited Regulations require, amongst other things, aircraft owners and operators to “have [the] 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 as9

9 prescribed in part 43 of this chapter. . . .”These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to my, Nick Komic, ( Coptervate Aerial Imagery, LLC ) 's, UAS. However, as a safety precaution I inspect my UAS before and a fter each flight.

A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procur ement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my UAS permits exemption from Part 21 because my, Nick Komic, ( Coptervate Aerial Imagery, LLC ) ’s, UAS meets an equivalent l evel of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation pe rmit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My UAS meets or exceeds each of the
elements. 14 C.F. R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this regu lation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved. In summary, Nick Komic, ( Coptervate Aerial Imagery, LLC ) seeks an exemption from the following Regulations:14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. §91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. §91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a) (2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commerc ially operate my, Nick Komic, ( Coptervate Aerial Imagery, LLC ) 's, small unmanned vehicle/lightweight unmanned aircraft vehicle in community awareness, education, structural inspection land management, search and rescue and real estate operations, and to de velop economic platforms for the aforementioned to enhance the experience of those seeking to relocate, rebuild, reevaluate and to find in the metro Detroit area.

F. Additional FAA Required Operating Conditions and Limitations

When not covered els ewhere in this Operations Manual, the following conditions and

limitations apply:10

10 1. The UA must weigh less than 55 pounds (25kg), including energy source(s)

and equipment

2. The UA may not be flown at a speed exceeding a ground speed of 85 knots.

3 . Flights must be operated at an altitude of no more than 500 feet above ground level
(AGL), as indicated by the procedures specified in the operator's manual. All

altitudes reported to ATC must be in feet AGL.

4. The UAS 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 state driver’s license.

5. All operations must utilize a visual observer (V O). The VO may be used to satisfy the

VLOS requirement, as long as the PIC always maintains VLOS capability. The VO
and PIC must be able to communicate verbally at all times.
6. If a discrepancy exists between these limitations and any procedure outlined elsewhere

in this operations manual, the conditions and limitations herein take precedence and

must be followed.
7. Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe
flight. If the inspection reveals a condition t hat 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, if utilized, must be included in the preflight inspection. All
maintenance and alterations must be properly documented in the aircraft records.

8. 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 in accordance with the operator's manual. The PIC who conducts
the functional test flight must make an entry in the UAS aircraft records of the flight.

9. The operator must follow the manufacturer 's UAS aircraft/component, maintenance,

overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft

maintenance/component/overhaul, replacement, and inspection/maintenance

requirements must be established and identified in th e operator's manual. At a minimum,
the following must be included in the operator's manual:

a. Actuators / Servos

b. Transmission (single rotor)11

11 c. Powerplant (motors)

d. Propellers

e. Electronic speed controller

f. Batteries

g. Mechanic al dynamic components (single rotor)

h. Remote command and control

i. Ground control station (if used)

j. Any other components as determined by the operator

10. The Pilot in Command (PIC) must possess at least a sport pilot certificate and at lea st a
current state driver’s license. The PIC must also meet the flight review requirements
specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his/her pilot

certificate.

11. Prior to operations conducted for the purpose of motion pictur e filming (or similar
operations), the PIC must have accumulated and logged, in a manner consistent with 14

CFR § 61.51 (b), a minimum of 200 flight cycles and 25 hours of total time as a UAS
rotorcraft pilot and at least ten hours logged as a UAS pilot wi th a similar UAS type (single
blade or multirotor). Prior documented flight experience that was obtained in compliance

with applicable regulations may satisfy this requirement. Training, proficiency, and

experience

- building flights can also be conducted un der this grant of exemption to
accomplish the required flight cycles and flight time. During training, proficiency, and

experience

- building flights, all persons not essential for flight operations are considered

non

- participants, and the PIC must operate t he UAS with appropriate distance from non

participants in accordance with 14 CFR § 91.119.

12. Prior to operations conducted for the purpose of motion picture filming (or similar
operations), the PIC must have accumulated and logged, in a manner consistent with 14
CFR § 61.51 (b), a minimum of five hours as UAS pilot operating the make and model of UAS

to be utilized for operations under the exemption and three take

- offs and three landings in the
preceding 90 days. Training, proficiency, experience

- building , and take

- off and landing
currency flights can be conducted under this grant of exemption to accomplish the required
flight time and 90 day currency. During training, proficiency, experience

- building, and take

- off
and landing currency flights, all persons not essential for flight operations are considered non

-12

12 participants, and the PIC must operate the UAS with appropriate distance from non

- participants
in accordance with 14 CFR § 91.119.

13. Prior to any flight operations authorized by this grant of exemp tion, the PIC and visual

observer (VO) must have successfully completed a qualification process, as outlined in

the operator’s manual. As this is a requirement stipulated by the operator, the test must be
developed and implemented by a qualified person des ignated at the sole discretion of the

operator. A record of completion of this qualification process must be documented and made

available to the Administrator upon request.

14. Prior to operations conducted for the purpose of motion picture filming (or s imilar
operations), a flight demonstration, administered by an operator

- approved and

- qualified pilot
must be successfully completed and documented. This documentation must be available for

review upon request by the Administrator. Because the knowledge an d airmanship test
qualifications have been developed by the operator, and there are no established practical
test standards that support a jurisdictional FAA FSDO evaluation and approval of company

designated examiners, the petitioner will conduct these te sts in accordance with the operator’s

manual.

15. The UAS may not be operated directly over any person, except authorized and consenting
production personnel, below an altitude that is hazardous to persons or property on the surface

in the event of a UAS failure or emergency.

16. Regarding the distance from participating persons, the operator’s manual has safety
mitigations for authorized and consenting production personnel. At all times, those persons

must be essential to the closed

- set film operations. Because these procedures are specific to
participating persons, no further FSDO or Aviation Safety Inspector (ASI) approval is
necessary for reductions to the distances specified in the petitioner’s manuals. This is

consistent with the manned aircraft proc edures described in FAA Order 8900.1, V3, C8, S1
Issue a Certificate of Waiver for Motion Picture and Television Filming

.

17. Regarding distance from non

- participating persons, the operator must ensure that no
persons are allowed within 500 feet of the ar ea except those consenting to be involved and
necessary for the filming production. This provision may be reduced to no less than 200 feet
if it would not adversely affect safety and the Administrator has approved it. For example, an13

13 equivalent level of sa fety may be determined by an aviation safety inspector’s evaluation of
the filming production area to note terrain features, obstructions, buildings, safety barriers,
etc. Such barriers may protect non

- participating persons (observers, the public, news med ia,
etc.) from debris in the event of an accident. This is also consistent with the same FAA Order
8900.1, V3, C8, S1. 18. If the UAS loses communications or loses its GPS signal, the UA

must return to a pre

- determined location within the security perimete r and land or be

recovered in accordance with the operator’s manual.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre

determined location within the security perimeter and land or be recovered in accordance

with the operator’s manual.

19. The UAS must abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the operator’s manual.
20. Each UAS operation must be completed within 30 minutes flight time or with 25%

battery power remaining, whichever occurs first.

21. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or
Authorization (COA) prior to conducting any operations under this grant of

exemption. This COA will also require the operator to reques t a Notice to Airman
(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the

operation.
22. All aircraft operated in accordance with this exemption must be identified by serial
number, registered in accordance with 14 CFR part 47 , and have identification (N

Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must

be as large as practicable.

23. The operator must develop procedures to document and maintain a record of the UAS

maintenance, preventative maintenanc e, alterations, status of replacement/overhaul

component parts, and the total time in service of the UAS. These procedures must be

added to the operator’s manual.
24. Each UAS operated under this exemption must comply with all manufacturer Safety

Bulletin s.

25. The operator must develop UAS technician qualification criteria. These criteria must be

added to the operator’s manual.
26. The preflight inspection section in the operator’s manual must be amended to include the
following requirement: The prefligh t inspection must account for all discrepancies, i.e.14

14 inoperable components, items, or equipment, not covered in the relevant preflight

inspection sections of the operator’s manual.
27. Before conducting operations, the radio frequency spectrum used for op eration and
control of the UAS must comply with the Federal Communications Commission (FCC) or

other appropriate government oversight agency requirements.
28. At least three days before scheduled filming, the operator of the UAS affected by this

exemption must submit a written Plan of Activities to the local FSDO with jurisdiction
over the area of proposed filming. The 3

- day notification may be waived with the
concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates an d times for all flights

b. Name and phone number of the person responsible for the UAS filming

production under this grant of exemption

c. Name and phone number of the person responsible for the on

- scene operation

of the UAS.

d. Make, model and seri al or N

- number of the UAS to be used

e. Name and certificate number of the UAS PIC's involved in the filming

production event

f. A statement that the operator has obtained permission from property
owners and/or local officials to conduct the filming pr oduction event; the
list of those who gave permission must be made available to the

inspector upon request.

g. Signature of exemption

- holder or representative

h. A description of the flight activity, including maps or diagrams of any area,

city, town, county, and/or state over which filming will be conducted and the

altitudes essential to accomplish the operation
29. The documents required under 14 CFR § 91.9 and § 91.203 must be available to the PIC
at the ground control station of the UAS any time th e aircraft is operating. These
documents must be made available to the Administrator or any law enforcement official

upon request.
30. The UAS must remain clear and yield the right of way to all other manned operations
and activities at all times (includin g, but not limited to, ultralight vehicles, parachute
activities, parasailing activities, hang gliders, etc.).15

15 31. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All

operations must be conducted under visual meteorological co nditions (VMC). Flights
under special visual flight rules (SVFR) are not authorized.
32. The UAS cannot be operated by the PIC from any moving device or vehicle.

33. The UAS 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.

34. The UAS may not operate in Class B, C, or D airspace without written approval from the
FAA. The UAS may not operate within 5 miles of the geographic center of a non

- towered

air port 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.

35. Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical
boundaries of the operational area as defined by the applicable COA must be reported to
the Federal Aviation Administration’s (FAA) 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. Further f light operations may
not be conducted until the incident, accident, or transgression is reviewed by AFS

- 80 and

authorization to resume operations is provided.

Currently, the aforementioned aerial videography/photography relies primarily on the use of

l arger aircraft running on combustible fuel. Posing potential risk to the public. Granting my, Nick Komic, ( Coptervate Aerial Imagery LLC) ’s, request for exemption will reduce current risk levels and thereby enhance safety. My UAS craft do not contain pot entially explosive fuel, is smaller, lighter and more maneuverable than conventional video and photographic aircraft with much less flight time. Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk flying to and from established airfields. I, Nick Komic, ( Coptervate Aerial Imagery LLC )

, have been informally analyzing and recording flight information and will compile safety protocols and the implementation of a flight operations manual for usage that exceeds currently accepted means and methods for safe flight. Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA Modernization and Reform Act of 2012. There are no pers onnel on board my, Nick Komic, ( Coptervate Aerial Imagery LLC ) ’s, UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. My, Nick Komic, ( Coptervate Aerial Imagery LLC ) ’s, operation of my UAS, weighing less than thi rt y

- five ( 35 ) pounds and traveling at lower speeds within limited areas low to the ground will provide an equivalent level of safety as that achieved16

16 under current FARs. Accordingly I, Nick Komic, (Nick Komic Photographic, Inc.) , respectfully request that the FAA grant my exemption request and am willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at large.

Respectfully submitted,

Nick Komic, ( Coptervate Aerial Imagery LLC )
7755 22 Mile Rd. # 183112 Shelby Township, MI 48318

- 7126

10

Appendix A



### List of Aircraft

No. Make and Model Description Serial No. Registration
No.
1 DJI Inspire 1 Electric powered, 4 r otor, small unmanned multirotor helicopter 

### Pending Pending

2 DJI Phantom 3 Electric powered, 4 rotor small unmanned multirotor helicopter 

### Pending Pending

3 Freefly Alta Electric powered, 6 rotor, small unmanned multirotor helicopter 

### Pending Pending

1. DJI INSPIRE ONE The operation of the DJI INSPIRE ONE system is as follows.

1. Build Materials
I. Plastic
II. Aluminum

2. Motor Configuration I. The DJI INSPIRE ONE flight in a 4 motor quadcopter setup.17

17 3. Payload

I. The DJI INSPIRE ONE flies it’s own light

- weight integrated camera.
II. Maximum All

- up weight

- 7.5 lbs

4. M aintaining the DJI INSPIRE ONE I. Before each flight: 1. Check all hardware to ensure it is securely tightened. 2. Check that the motor is level and locked in place. 3. Check the propeller to ensure it is tight and there are no visible signs of cracks, str ess, 4. Check all wiring to motors, motor controllers, batteries, and flight controller for signs of 5. Check all navigational lighting to ensure it is properly working.

II. After 45 hours of flight
1. Remove and check all motors and motor mounts for si gns of wear and tear. Replace as

necessary. 2. Remove motor controllers and visually inspect and check for damage. Replace as necessary. 3. Remove flight controllers and visually inspect and check for damage. Replace as necessary. and/or chips. Replace if propeller is questionable. 4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying. 5. Check for updates to flight controller firmware. If available, install and perform a minimum of 15 test flights before conductin g commercial work.

Appendix B
2. DJI Phantom 3 The operation of the DJI Phantom 3 system is as follows.

1. Build Materials
I. Plastic
II. Aluminum

2. Motor Configuration I. The Phantom 3 flight in a 4 motor quadcopter setup.

3. Payload
I. The Pha ntom 3 it’s own integrated camera.
II. Maximum All

- up Weight

- 4lbs

4. Maintaining the Phantom 3 I. Before each flight: 1. Check all hardware to ensure it is securely tightened. 2. Check that the motor is level and locked in place. 3. Check the propeller to ensure it is tight and there are no visible signs of cracks, stress,18

18 4. Check all wiring to motors, motor controllers, batteries, and flight controller for signs of damage. 5. Check all navigational lighting to ensure it is properly working.

II. After 45 hours of flight 1. Remove and check all motors and motor mounts for signs of wear and tear. Replace as

necessary. 2. Remove motor controllers and visually inspect and check for damage. Replace as necessary. 3. Remove flight controllers and visually i nspect and check for damage. Replace as necessary. and/or chips. Replace if propeller is questionable. 4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying. 5. Check for updates to flight controller firmware. If ava ilable, install and perform a minimum of 15 test flights before conducting commercial work.

Appendix C
3. Freefly Alta The operation of the Freefly Alta system are as follows (the flight controller operation manual is NOT explained in this manual but ca n be found in Appendix E, Section 1).
1. Build Materials
I. Carbon Fiber
II. ABS Plastic
III. Stainless Steel Hardware

2. Motor Configuration

I. Alta configuration utilizing 6 motors ( Direct Drive 3

- Phase PMAC Outrunner ) which

, is powered by the Fre efly Silent

- Drive Sine Wave ESC m otor controller. The motors are configured with 1 motor per arm

. We have tested this situation and can confirm it works as
described.

II. In this configuration the Freefly Alta can handle up to two (2 ) motors failing and still be able to fly.

3. Payload
I. The Freefly Alta will carry the Freefly Systems MoVI M5, M10, or M15 camera gimbal.
II. The cameras that will be flown on the Freefly Alta include, but are not limited to, Canon 5DMKIII, Canon C

- 100, Canon C

- 300

, Blac k Magic Micro Cinema, RED Epic, RED Dragon,
Panasonic GH

- 4 and Sony FS700.
III. Maximum All

- up Weight

- 34lbs

4. Maintaining the Freefly Alta I. Before each flight: II. After 45 hours of flight

1. Check all hardware to ensure it is securely tightened.

2. Check that all motors are level and locked in place.19

19 3. Check all propellers to ensure they are tight and there are no visible signs of cracks, stress, and/or chips. Replace if any propeller is questionable. 4. Check all wiring to motors, motor controll ers, batteries, and flight controller for signs of cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying. 5. Check all navigational lighting to ensure it is properly working. 6. Remove and check all motors and motor mounts for sign s of wear and tear. Replace as

necessary. 7. Remove motor controllers and visually inspect and check for damage. Replace as

necessary. 8. Remove flight controllers and visually inspect and check for damage. Replace as necessary. Check for updates to fli ght controller firmware. If available, install and perform a minimum of 15 test flights before conducting commercial work.

Appendix D

Personal Protocols/Controls/Flight Manual
Protocols and Controls

Nick Komic ( Coptervate Aerial Imagery, LLC. ), She lby Township, Michigan.

Safety for public on the ground as well as manned aircraft above is an essential and utmost consideration for aerial videos and photography. As such, safety protocols and controls must be implemented through preflight preparation and during flight. PreFlight Protocol:

Che ck batteries with voltage meter to insure fully charged and ready for use.

Inspect batteries for damage or leakage that may affect proper operation.

Inspect propellers for cracks, chips or damage that may cause sudden loss of propulsion or unmanageabl e/uncontrolled flight.

Check all GPS and Telemetry connections prior to flight.

Check weather forecasts for wind advisory or other conditions that my impact flight.

Consult Sky Vector aeronautical Charts (Skyvector.com)for airport vicinity and flight paths of possible air traffic.

Contact respective airport to advise of estimated flight time, estimated flight duration, estimated elevation of flight, and any other pertinent information.20

20 Inspect flight area for Vicinity of public safety helipads /heliports Vicinity of medical helipads/heliports Vicinity of light poles vicinity or utility wires Vicinity of trees flocks of birds that may cause interference and potential flight impact Vicinity of any elevated obstructions that may pose potential fl ight hazard Vicinity of roadways with moderate to heavy traffic that can be distracted public Gatherings that may attract viewers optional point of control for best visual site of UAS while in flight Emergency landing areas

Takeoff and landing

Inspec t area for best and safest point of takeoff and landing If in a subdivision or area that is within 150 feet of a residential street, post warning Sign(s)/stand(s) "Attention Aerial Photography In Progress  Remain Back 150 Feet "

Flight Protocol: takeof f and land from same location ( have alternate landing areas in case of emergencies) remain alert to birds, sound or aircraft, curious public, and a pproaching vehicles do not allow anyone to engage in conversation or distract the remote control pilot restrict flight to minimal elevation sufficient to acquire desired results remained prepared for emergency landing at all times pay attention to flight t ime

– warning meter for low voltage.

Set voltage meter alarm for low voltage and flight timer as a safety alert land UAS and shut down propulsion immediately following landing

– priority of disconnecting batteries

Post flight:

1. a) Disconnect batter y to prevent accidental activation of propulsion system

2. b) Secure UAS in a safe location

c) Remove all warning signs from public access areas Emergency or Suspected Hazard:

Immediate land UAS at safest and closet ground location in the event

Man ned aircraft is heard or seen in vicinity of flight There is a public gathering within established safety boundary wanting to observe flight Pilot is being distracted from focusing on flight and safety Sudden change in weather (wind bursts)
Sudden incr ease in vehicular traffic in vicinity of flight Birds enter into proximity of flight Any sudden unsafe event that can cause collision, distraction or interruption of control21

21 Safety for public on the ground as well as manned aircraft above is an essenti al and utmost consideration for aerial videos and photography.

Maintaining a record of safe flight for FAA request and for determining future UAS safety protocols is imperative.

Date:____________________ Location:____________________________________

_______________

preflight Inspection:

o Yes o No

Comment: _________________________________________________

Elements

Proximity to airport: _________________ (see attached map pinpointing approximate location of flight)

Airport notified: No Yes

Date:_______________ Time: ______________

Phone Number: _______________________ Contact Name:___________________________________

Nearest major intersection:

______________________________________________________________

Proximity to medium traffi c road:

_________________________________________________________

Proximity to heavily traveled roadway road:

_________________________________________________

Proximity to congested population:

________________________________________________________

Approx. Takeoff Time : GMT:

Weather Good Fair Poor Comment :22

22 Visibility Good Fair Poor Comment :

Wind Speed ___mph ___Gusts/MPH ___avg/MPH Comment :

Approx. Landing Time: GMT: Estimated Elevation Ground level: Safety Concerns:
Additional Commen ts:
sea level:

Appendix 'D'



### Aircraft Manuals

This Appendix includes UAS manufacturer's user manuals, maintenance instructions, and illustrated parts catalogs. These manuals may be attached to the docket when submitted. Information regarding design, aircraft performance, fail

- safe features, operating limitations, normal and emergency procedures, and maintenance and inspection procedures is contained within the manuals and supplemental information documents listed below:

1. DJI Inspire Manual V1.0 2. Inspire 1 Maintenance Manual v1.0 3. Intellig ent Flight Battery Safety Guidelines v1.4 4. Inspire 1 Safety Guidelines 5. Phantom 3 Professional Manual V1.0 6. Phantom 3 Intelligent Flight Battery Safety Guidelines v1.0 (EN) 7. Freefly Alta Aircraft Flight Manual 8. Freefly Alta Set Up Guide

For more information or questions about this manual please contact:

Coptervate Aerial Imagery, LLC

. 48172 Bluebird Dr. Shelby Township, MI 48317 (248) 890

- 2189