### Michael Drake **(Cochise Aerial Perspective , LLC**  **) , Sierra Vista AZ** 
**- Section 333**  **Exemption Petition** July 24 , 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 , subpart H ; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 91.119; 91 .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, Michael Drake , owner of Cochise Aerial Perspective , LLC am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. Part 11, to request that Cochise Aerial Perspective , LLC , an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (FARs) listed below

. Such an exemption will allow for the commercial use of small ultra

- light unmanned aircraft system s (sUAS) within the United States national airspace system regulated by the Federal Aviation Administration (FAA). As described herein , Cochise Aerial Perspective , LLC is a commercial for profit entity serving the Cochise County and greater, Arizona area with aerial photography and video to private and public entities upon request

. Our intent is to provide other commercial enterprises (i.e. real

estate companies, professional photographers, contractors, government bodies and institutions of higher learning) an opportunity to enhance their product line, marketing prowess and / or overall situational awareness with an aerial perspective

. In order to accomplish this, Cochise Aerial Perspective , LLC intends on utilizing the DJIInspire 1 (initial platform of choice). The aerial perspective provided will not only enhance the ability o f local entities to better market themselves, but also make smarter / better business decisions, enhance / promote community awareness, and potentially provide institutions of higher learning an additional tool to utilize in their research efforts. Additionally, videography / cinematography may provide community planners, builders, as well as real estate owners a better understanding and perspective to more adequately address their properties needs while more importantly taking into account potential impact to the surrounding area / areas. With well over forty (40) years of combined experience flying both manned and unmanned aircraft and a sound understanding of the various ty pes of airspace within and surrounding Cochise County, Cochise Aerial Perspective, LLC is committed first and foremost to safety

. To assist in this endeavor, Cochise Aerial Perspective, LLC will maintain a safety, currency, training and maintenance program in addition to other checks and balances.To assist in this endeavor, we have Mr. Ross Miller who as Chief Knowledge Officer (CKO )

brings to the forefront expertise within the field of aviation

. His manned qualifications include the following: commercial instrument CFI( airplanes and helicopters); CFII airplanes; and advanced and instrument ground instructor. Combined with our shared unmanned experience (former qualified Shadow operators / instructor), knowledge of regulatory b odies (i.e. FAA) and their associated mandate s (i.e. Certificates of Authorization, FARs, LOPs), as well as knowledge pertaining to local airspace (i.e. SUAS, restricted airspace, temporary f light restrictions (TFRs) ) common to the area of operations ; we feel Cochise Aerial Perspective , LLC is poised to represent this burgeoning industry well

. Of significance and worthy o f mention are the risk factors posed by an ultra

- light remote control (RC) aircraft versus a manned platform utilized for similar purposes. The upside for unmanned operations at this scale is signific ant. There is little to no risk to crew, and taking into consideration anticipated operating space (both vertical as well as lateral), very little to other aircraft. Extraneous factors such as noise and air pollution as well as potential impact to the environment are greatly reduced as well. Succinctly, Cochise Aerial Perspective is committed to safety with each and every

f light and respectfully requests an exemption to the following: Exemption Request Section 333 of the FAA Reform Act o f the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21, subpart H; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b). On a macro level, in order to better facilitate the tracking of unmanned aircraft operations and future transition of UAS into the NAS as a whole , Cochise Aerial Perspective , LLC will record all pertinent data as mandated by the Federal Aviation Administration (FAA) for any and all ultra

- light weight, remote control aircraft operations. This includes but is not limited to training, maintenance, and operational flights. Data to include but not limited to take

- off date and time, return, total flight time, cumulative flight time, delays due to extraneous circumstances (i.e. weather), visual observer information, and any a pplicable training will be kept and provided to the FAA as necessary

and / or required. Actions such as these we hope will provide the general public as wel l as requisite / interested governmental bodies a more thorough and complete understanding of the positive impact unmanned operations will have. Granting Cochise Aerial Perspe ctive’s request comports with the Secretary of Transportation’s (FAA Administrator’s) responsibilities and authority 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 commercial purposes. In order that Cochise Aerial Perspective , LLC is able to conduct operations in compliance with the protocols describ ed herein or as otherwise established by

the FAA, associated references will be utilized as required to include but not limited by the following: 1) 14 CFR Part 91, General Operating and Flight Rules 2) FAA Flight Standards 8900.1 CHG 351, Vol 16 Unmanned Aircraft S ystems, 23 Jun2014

3) FAA NOTICE 8900.268, Education, Compliance and Enforcement of Unauthorized Unmanned Aircraft System Operators, 15 Jul 14 4) FAA Order JO 7110.65, 09 FEB 2012, Air Traffic Control 5) FAA Notice 8900.227, 30 JUL2013, UAS Operational Approval 6) FAA Notice JO 7210.873, 11 July 14, UAS Operations in the National Airspace S ystem (NAS) 7) FAA AC 91

- 57, Model Aircraft Operating Standards 8) Federal Register Vol. 80, No. 35 (Part III) Insummary, f

or reasons outlined below, Cochise Aerial Perspective , LLC respectfully requests the grant of an exemption allowing it to operate ultra

- light weight, remote controlled UAS’s for various commercial applications including but not limited to academic research, community awareness , wildlife management, erosion control, and real

- estate marketing purposes. We believe each of these proposed applications has the potential for stimulating economic growth, community

awareness, safety and overall interest in the Cochise County and surrounding areas. **I. Applicant**  **Contact Information** : Cochise Aerial Perspective , LLC Michael Drake (Owner) 2457 East Kalispell Ave. Sierra Vista, AZ 856 50 Office: (520) 255

- 3776 Home: (520) 559

- 3542 Email: ecuaz09@msn.com **II. The Specifi** **c Sections of Title 14 of the Code of Federal Regulations From Which Cochise Aerial Perspective** **, LLC Requests Exemption are:**  14 CFR 21 , subpart H ; 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). Appendix D

- Personal Protocols and Controls
**III. The**  **Extent of**  **relief Cochise**  **Aerial Perspective** **, LLC**  **seeks and**  **Reasoning for**  **said Relief:**
Cochise Aerial Perspective , LLC submits this application in accordance with the Reform Act, 112 P.L . 95 §§ 331

- 334, seeking relief from any currently applicable FARs restricting Cochise Aerial Perspective , LLC from proposed commercial flight operations within the national airspace system (NAS)

. The Reform Act in Section 332 provides for such integration of civilunmanned aircraft systems into our national airspace system as it is in the public’s interest to

do so. Our ( Cochise Aerial Perspective , LLC ’s ) ultra

- light weight UAS meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore its integration is expressly c ontemplated by

the Reform Act. We respectfully request permissions to operate our ultra

light weight UAS prior to the time period by which the Reform Act requires the FAA to solidify rules governing such craft. Taking into consideration the aviation related knowledge base within Cochise Aerial Perspective , LLC combined with proposed safety measures and standard operating procedures, granting such release will allow for early insight into the viability of allowing unmanned civil aircraft into the NAS. The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspace s ystem. Considerations 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 b y line of sight. 112 P.L . 95 § 333 (a). Each of these items reflects in favor of an exemption for Cochise Aerial Perspective , LLC . Our UAS utilizes four (4) counter

-rotating propellers for balance, control and stability and is equipped with GPS and auto return safety techno logy . Weighing less than five (8 ) pounds (far below the maximum 55 pound limit); including camera with gimbal our aircraft falls well within these parameters. In summary, we are seeking relief to restrictions already outlined for amendment in Federal Register Vol. 80, No. 35, dated February 23 , 2015.
**IV. How**  **Cochise Aerial**  **Perspective ,**  **LLC ’s**  **Request Will**  **Benefit the**  **Public As**  **A Whole:**  The use of unmanned systems as a whole has been a topic of much debate with NAS integration at the forefront

. However, many in the unmanned community who have a finger on the pulse of unmanned technology

and its capabilities and limitations are understandably, generally more pro - integration (into the NAS)

. An unfair advantage exists in that they s imply p ossess a more in

- depth understanding of unmanned systems , perhaps in part at times due to the nature of their work. A lot of misconceptions regarding unmanned systems, their safety or lack there

- of , privacy i ssues, etc. exist , but with a more sound knowledge base, many o f these pitfalls (misconceptions) held by the general public could be minimized

. Cochise Aerial Perspective , LLC feels this much anticipated milestone of UAS integration into the NAS provides an extraordinary opportunity to do just that , provide the public with a better understanding of unmanned systems and their overall benefit

. It is a huge responsibility with equal upside. For the general public as well as government municipalities, we hope to provide a service that up until this point may

have been unavailable , whether due to fiscal, airspace, safety or other concerns. With the affordability that this system will provide , obstacles that previously may have seemed insurmountable may b e crossed

. The pictures and video we hope to be able to provide will give public and private se ctor entities alike an added dimensional perspective enabling resolution to challenges in a safer and more cost effective manner. We fully expect to be able to provide a service that will prove invaluable across the f ull spectrum of potential users whether business, academic or municipal in nature

. History has demonstrated that given time, new technology

will pave the way

f or solutions to challenges outside the initial scope of intent. It is our hope and expectation that previously unrecognized solutions and potential uses will bediscovered through everyday use. The general public to include governmental entities will have at their disposal access to cheap overhead aerial coverage. Businesses will have an opportunity to better promote their product, indivi duals will possess an opportunity to better prepare themselves in the decision making process, public entities will be much better equipped to observe and effect areas of responsibility

(i.e. water run- off / drainage), land developers will make smarter and more ecologically friendly decisions regarding our environment

. These are just a few areas in which we feel we can provide a positive impact to the general public. **V. Reasons**  **Why Cochise**  **Aerial Perspective** **, LLC**  **’s Exemption**  **Will Not**  **Adversely Affect**  **Safety Or**  **How The**  **Exemption Will**  **Provide a**  **Level of**  **Safety At Least Equal To Existing Rule:**  Cochise Aerial Perspective , LLC understanding the importance of this milestone, will take every precaution and opportunity to not only educate, but allay s ome of the inhibitions held by the general public regarding unmanned systems and their use in place of manned systems

. We will take this as an opportunity to better educate the public as well as provide an invalua ble service, unreachable to many until this point. This a ll begins and ends we understand with a stellar safety record

. A proven safety

record c ombined with the opportunity to possess affordable enhanced situational awareness will provide an additional pathway to success for the general public as well as the unmanned community

. Utilizing manned aviation practices regardless of the size of the unmanned system or scope of work will help instill a sense of understanding and trust for what until this point has been a misrepresented and misunderstood technology

. Example s afety protocols will include the following : 1) Strict adherence to air vehicle maintenance

. Pilot will preflight/inspect sUAS for airworthiness prior to each flight including the ground c ontrol station (GCS)

. 2) This sUAS weighs less than 8 lbs. 3) Anticipated average operating speed of < 42 knots. 4) Constant / consistent training regarding safety of flight 5) Vigilance to weather conditions that may prohibit flight and staying well clear of obstacles (i.e. buildings, towers)

. 6) Crew for each operation will consist of (at a minimum) the sUAS Pilot who will keep the sUAS within his / her visual line of sight at all times and a Visual Observer (VO) who will also keep the aircraft within line of sight as well as watch for other aircraft or personnel that might enter the operations area. 7) Pilot and visual observer (VO ) will keep in constant verbal contact throughout the duration of each flight. I f conventional aircraft or unauthorized personnel enter the flight operations area unexpectedly, flight operations will be terminated immediately

. 8) C lear and concise visual observer (VO) training

. 9) Integrated safety systems: if the battery r uns low or connection with the remote controller is lost, the Inspire 1 uses its positioning system and smart flight technology to return back to you.10) Utilization of safety buffer within a predetermined operating space at all times, situation

dependent (i.e. stay

well clear of all airports / airfields ; more than 5 miles as shown on current FAA

-published aeronautical charts unless authorization has been granted by the controlling ATC facility

governing that airport)

. 11) Warning signs will be posted in the flight operations area indicating to remain clear of the area. 12) Differ to conservative values regarding s ystem capabilities and limitations at all times

. 13) Maintain an operational log (integrated automatic flight logs) , recording all flights and any p oints of interest or lessons learned and taking a proactive stance analyzing and recording flight data for future reference

. 14) Pilot will conduct a functional test flight after all maintenance prior to the next operational flight and record this flight in the Inspire 1 records/ flight log. 15) Intelligent Battery updating status and remaining available power in real time continuously

c alculating its current distance from you and the amount of power needed for safe return

. 16) Only f ly with a battery

charged above the minimal charge level for safe operation and swap out old for new batteries (battery log) well prior to obsolescence

. 17) Reserve batteries on hand at all times with additional back

-up aircraft

. 18) Educate / train / enforce utilization of crew resource management (CRM)

. 19) Training flights whenever not actively engaged with a client 20) All flights will be conducted well below the 400 foot ceiling (AGL) as mandated by the FAA Modernization and Reform Act of 2012 with the majority below 200 foot AGL 21) Maintain line of sight (LOS) operations at all times

. 22) A mandatory

briefing for all flight operation participants will be conducted prior to any and all sUAS operations prior to each flight 23) Written and/or oral permission from the relevant property holders will be obtained. 24) All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire or other appropriate governmental agencies when required. 25) The pilot will take all actions including reviewing weather, flight battery requirements , landing and takeoff distances and aircraft performance data before initiation of flight. 26) The pilot will have a minimum of 200 flight cycles and 25 hours of total time as a sUAS rotorcraft pilot and at least 10 hours specific to piloting the DJIInspire 1 to be utilized for operations under the exemption. 27) The pilot will perform a minimum of 3 takeoffs and landings within the preceding 90 days with the Inspire 1 sUAS. 28) The pilot will abort a flight (return to home) in case of unpredicted obstacles or emergencies with the push of a button. Please refer to DJ I Inspire 1 User Manual page 28. 29) All flights will be flown only d uring daylight hours under visual meteorological conditions (VMC). Training is a proven and established means by which to ensure safety of f light operations. Our intent is to train whenever we are not providing a service

. This training will include ground based as well as flight training incorporating a high level of fidelity and realism as well as being scenario based. Additionally, w e will seek and maintain open lines of communication with any and all aviation organizations within the area of operations to promote a heightened level ofawareness and understanding as well as safety. We will attend training and other aviation

related conventions that may have an impact on our situational awareness in regard to any and all safety related items of interest. When afforded the opportunity, we would prefer to participate in and support these and similar events. As noted above, visual observers will also be utilized to ensure safety of flight. Separate and distinct training will be provided to all VOs clearly delineating duties and responsibilities

. A visual observer training syllabus can be provided upon request

. Additionally, the aircraft we will b e using has imbedded “Smart Return to Home (RTH) ” technology

which has the following attributes or safety features: Smart Return to Home (RTH) includes three available modes: Failsafe , Return Home , and Dy namic Home Point. Failsafe Return to Home is activated automatically i f remote control signal (including video relay) is lost for more than 3 seconds provided the Home Point has been successfully recorded and compass is working normally. Return Home process may b e interrupted and the operator can regain control over the aircraft if link is reestablished. Return to Home brings the aircraft back to the last recorded Home P oint. There are three cases that will trigger RTH procedure; they are Smart RTH, Low Battery RTH, and Failsafe RTH. Dy namic home point is useful in situations when you are in motion and require a Home Point that is different from the take

- of point.
Inc onclusion , we feel there is substantial if not overwhelming evidence indicating that use of our unmanned system within the parameters previously discussed and / or outlined provide s for a reduced risk to all: reduced risk to crew , reduced risk to the general public, and reduced risk to the environment. To quote from the Federal Register / Vol. 80, No. 35, “The FAA has selected this appro ach because it would allow lower

-risk small UAS operations to be incorporated into the NAS immediately instead of waiting until the issues associated with higher

-risk UAS operations are resolved.”
**VI. DESCRIPTION OF SPECIFIC REGULATIONS REQUESTING EXEMPTION**  **FROM: 14 CFR Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203(a)(1)**  Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the limited size and anticipated operating area of our aircraft , an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 V.S.C.§44701 (t) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular sUAS. Our small UAS will be operated at low speed in a controlled environment, at least five miles from any airport / airfield or similar facility (i.e. landing pad) and more than three miles from any den sely populated area. Taking into consi deration these criteria in addition to proposed safety precautions, restrictions and conditions outlined earlier, it is evident that a sUAS operating without an airworthinesscertificate is as safe if not safer than conventional aircraft (fixed wing or helicopter) operating

with an airworthiness certificate without the restrictions and conditions proposed. The DJ I Inspire 1 weighs less than 8 lbs. fully loaded and carries neither pilot nor passenger with no explosive materials or flammable liquid fuels. Its flight path will be predetermined as well as restricted to a secure area. Like other civil aircraft, operations under this exemption will be tightly

c ontrolled and monitored by all crew members and in compliance with local public safety requirements, only with additional safeguards and security provisions

. These safety

enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, S ubpart H. **14 C.F.R. 45.23(b): Marking of the Aircraft** This regulation requires certain experimental, provisionally certificated aircraft, or lightsport category aircraft be marked (identified) with letters between 2 inches and 6 inches high “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” near each entrance to a cabin, cockpit, or pilot station. Even though the sUAS will have no airworthiness certificate, an exemption would be needed as the sUAS will have no entrance to the cab in, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the sUAS, two
- inch lettering would be impossible. The FAA has issued an exemption to this regulation: Exemption No. 11109. **14 C.F.R. 61.113(a) & (b): Private pi lot privileges and limitations: Pilot in Command**  Sections 61.113 (a) & (b) limit private pilots to non- commercial operations. B ecause the sUAS will not carry

a p ilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the pilot operating the sUAS to have compl eted sUAS flight training by reviewing each of the three DJI Inspire 1 manuals (attached to this document), review all DJIInspire 1 tutorial videos listed at www.dji.com/product/inspire

- 1/video

. The pilot would also perform a minimum of 200 flight cycles, 25 hours of total time as a sUAS rotorcraft pilot and a minimum of 10 hours of piloting the Inspire 1 before performing the first “operational flight” under this exemption. Unlike a conventional aircraft that carries pilot and passengers, the sUAS is remotely controlled with no living thing or cargo on board. Additionally, the area of operation i s controlled and restricted with all flights planned and coordinated in advance. Subsequently, it may b e reasonable to assume that the ri sk of sUAS operations (within parameters previously discussed) is minimal as compared to that posed by the commercial operations for which this regulation (Part 61) was initially drafted

. Therefore , we feel allowing sUAS op erations as requested with a pilot who has met the minimum requirements stated above exceeds the present level of safety achieved b y 14 C.F.R. §61.113 (a) & (b).**14 C.F.R. 91.7(a): Civil aircraft airworthiness**

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. With no airworthiness certificate (as yet) issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the requirements contained in the DJI Inspire 1 Manuals, DJIInspire 1 tutorials in addition to the use of a preflight checklist prior to each flight , an equivalent level of safety will be provided. **14 C.F.R. 91.9(b)(2): Civil aircraft flight manual, marking and placard requirements** The sUAS, given its size and configuration cannot satisfy this requirement by

“ letter of law”. However, the intent of this regulation can be met by alternative means. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. **14 C.F.R. 91.103(b): Preflight Action** This regulation requires each pilot in command (PIC) conduct certain specific pre - flight actions ensuring safety of flight. An exemption is needed from this requirement as the pilot will ex ecute separate commensurate preflight checks to include checking weather conditions (current and forecasted) , checking flight battery status, verifying takeoff and landing distances, and all other actions in the Preflight Checklist as specified in the DJIInspire 1 Manuals. These actions will provide an equivalent level of safety. **14 C.F.R. 91.109: Flight Instruction** Section 91.109 states no person may operate a civil aircraft (except a manned free balloon) being used for flight instruction unless that aircraft has fully f unctioning dual controls. Small UAS and remotely p iloted aircraft (RPA) do not ty pically have fully

f unctional dual controls. Flight control is accomplished through the use of a control box that communicates / controls the aircraft via a hand

-held radio transmitter

. However, the FAA has previously approved exemptions for aircraft without fully f unctional dual controls (Exemption Nos.5778K & 9862A)

. An equivalent level of safety is provided when taking into consideration that neither pilot nor passengers are carried in the aircraft, the ability to control the sUAS via radio signals from the controller, and the minimal siz e and speed of the aircraft. **14 C.F.R. 91.119: Minimum Safe Altitudes** Section 91.119 establishes safe operating altitudes for civil aircraft

. Section 91.119 (d) permits helicopters to operate at l ess than the minimums mandated, provided the personoperating the helicopter complies with any route and / or altitude prescribed by the FAA ( controlling facility)

. Though almost identical from an aerodynamic and flight characteristic point of view (i.e. vertical takeoff and vertical landing) and ty pically operating at an altitude of 150’ AGL , we respectfully request an exemption given the difference (multi

-rotor craft) however minimal some may suggest. Our sUAS will never operate at an altitude higher than 400 ’ AGL and will be in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent

. In addition to a confined and secure area for flight operations, an equivalent level of safety wil l be achieved due to the relatively small size and weight and slow speed of the sUAS . And for situational awareness, advance notice will be provided to any and all onsite personnel and / or affected individuals regarding planned flight operations. Furthermore, until requisite permission s from interested parties (i.e. property owners , local officials ) are provided, f light activity will not be conducted

. Juxtapose the use of our sUAS with that of a manned platform (fixed or rotary
-wing) conducting a similar flight path or mission set and inherently, the sUAS poses less risk. Our aircraft weighs roughly 8 lbs. , not a thousand plus, does not carry flammable fuel, possesses built in return home (point of origin) logic, has no aircrew or passengers, is a carbon non- emitter, and in the event of an emergency l anding pose s little if any risk to the environment, surrounding structures or personnel. In addition, the low

- altitude nature of sUAS operations will by their very

nature ensure separation between it and that of conventional aircraft that must comply with Section 91.119. **14 C.F.R. 91.151(a): Fuel requirements for flight in VFR conditions** Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. The Inspire 1 will operate within a predetermined and controlled environment while possessing limited range and flight time , requiring an exemption from 14 CFR 91.151(a). The battery

p owering the Inspire 1 provides approximately 1 8 minutes of powered flight. Consequently, for the DJI Inspire 1 to meet the 30 minute reserv e requirement outlined in 14 CFR §91.151 is impossible. Given the In spire 1s limiting factors , a time frame of 14 minutes for flight in daylight VFR conditions may be more reasonable. Cochise Aerial Perspective , LLC believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lo ckheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the DJI Inspire 1 as proposed with less than 30 minutes of reserve fuel , in an area cordoned off for only those with signed waivers (i.e. property owners, official representatives ) does not generate the ty pe of risk Section 91.151(a) was intended to address given the size and speed of the Inspire 1

. Additionally, limiting In spire 1 flights to 14 minutes or less would significantly reduce the exemption s applicability

. An equivalent level of safety will be achieved by ensuring a predetermined battery reserve (20%) be maintained aided by an onboard monitoring system and the pilot for return to the ground control station. This restriction would be more than adequate to return the Inspire 1 to its planned recovery

area from anywh ere within its limited operating range . Further, the pre -flight checklist will include verification of available pre - determined flight termination points

to safely recover in the event a return to the point of origin is not an option. Similar ex emptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808. **14 CFR 91.203 (a) & (b):**  **Carrying civil aircraft certification and registration** The regulation provides in part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate .... (b) No person may

operate a civil aircraft unless the airworthiness certificate required by

p aragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The DJI Inspire 1 fully

loaded weighs no more than 8 lbs. and is operated without passengers or crew . Carrying certification and registration documents onboard is neither feasible nor beneficial

. An equivalent level of safety will be achieved keeping these documents at the ground flight control point. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. **14 C.F.R. 9 1.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance inspections**  These regulations mandate an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ... ,” and others shall inspect or maintain the aircraft in compliance with Part 43. As these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections would not apply to Cochise Aerial Perspective , LLC

. Maintenance will be accomplished by

the operator. An equivalent level of safety will be achieved becaus e the DJI Inspire 1 is very

limited in size while c arrying a small paylo ad and operating only in restricted areas for limited periods of time. Operating at no more than 400’ AGL, i f mechanical issues arise , the DJ I Inspire 1 can be recovered immediately

. A s noted earlier, when applicable , flight termination points (FTP) will be established prior to the flight as alternate recovery points in the event an issue develops with the aircraft. More importantly, the operator will pre flight the aircraft prior to each flight, perform required maintenance as well as preventivemaintenance checks and services (PMCS), while maintaining a log of any ma intenance

performed. The operator is the person most familiar with the DJI Inspire 1 and therefore best suited for maintaining it in an airworthy condition and providing an equivalent level of safety.

Pursuant to 14 C.F.R. Part 11, the following summary i s provided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b); 14 C.F.R. §§ 61.113( a) & (b); 91.7(a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (8 lbs. or less) in aerial photography and videography f or mapping, inspections of drainage ways and detention ponds, utilities, construction industries and real estate properties and other flight operations that could be performed safely and more cost effectively with the use of small UAS at low altitude within the U.S. National Airspace System as compared to manned aircraft. Approval of exemptions allowing commercial operations of sUASs enhances safety while reducing risk. Manned aircraft create a greater risk because the craft are much larger, have combustible fuel, and carry an onboard human pilot. Inc ontrast, a sUAS weighing fewer than 8 lbs. and powered by

batteries eliminates virtuall y all of that risk given the reduced mass and lack of combustible fuel carried on board. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation of small UASs, weig hing less than 8 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing co mmercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people. **Privacy** All flights will occur over private or controlled access property with the property owner's prior consent and knowledge. Images taken will be of individuals who have also consented to being filmed or otherwise having agreed to be in the area where aerial photography will take place. Every

precaution will be taken to ensure that any and all privacy c oncerns are more than adequately

addressed.

******** Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

– size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and natio nal security

– provide adequate justification (we feel) for the grant of the requested exemptions allowing commercial operation of Cochise AerialPerspective LLC ’s sUAS in above referenced services pursuant to the DJI Manuals attached

hereto. 1) http://download.dji

-innovations.com/downloads/inspire_1/jp/Inspire_1_User_Manual_v1.0_jp.pdf 2) http://downl oad.dji

-innovations.com/downloads/inspire_1/en/Inspire_1_Safety_Guidelines_en.pdf 3) http://download.dji

- innovations.com/downloads/inspire_1/en/Inspire_1_Maintenance_ManualV1.0_en.pdf Thank you for your time in considering this exemption request.

Sincerely,

Michael Drake Cochise Aerial Perspective , LLC Owner