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 

systems (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. realestate 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 DJI Inspire 1 (initial platform of choice). The

aerial perspective provided will not only enhance the ability of 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 types 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 bodies (i.e. FAA) 

and their associated mandates (i.e. Certificates of Authorization, FARs, LOPs), as well as 

knowledge pertaining to local airspace (i.e. SUAS, restricted airspace, temporary flight 

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 of 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 significant. 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 flight and 

respectfully requests an exemption to the following:

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).

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 applicable 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 well as requisite / interested governmental bodies a more thorough and complete 

understanding of the positive impact unmanned operations will have.

Granting Cochise Aerial Perspective’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 described 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 Systems, 23 Jun 
2014

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 JUL 2013, UAS Operational Approval

6) FAA Notice JO 7210.873, 11 July 14, UAS Operations in the National Airspace System 

(NAS)

7) FAA AC 91-57, Model Aircraft Operating Standards

8) Federal Register Vol. 80, No. 35 (Part III)

In summary, for 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 85650

Office: (520) 255-3776

Home: (520) 559-3542

Email: ecuaz09@msn.com

II. The Specific 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 civil 
unmanned 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

contemplated by the Reform Act. We respectfully request permissions to operate our ultralight 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 system. 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 by 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 technology. 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 simply possess 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 issues, etc. exist, but with a more sound knowledge base, many of 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 be crossed. The pictures and video we hope to be able to 

provide will give public and private sector 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 full spectrum of potential users 

whether business, academic or municipal in nature. History has demonstrated that given time, 

new technology will pave the way for solutions to challenges outside the initial scope of intent. 

It is our hope and expectation that previously unrecognized solutions and potential uses will be 
discovered 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, 

individuals 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 some 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 invaluable 

service, unreachable to many until this point. This all begins and ends we understand with a 

stellar safety record.

A proven safety record combined 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 safety 

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 control 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. If conventional aircraft or unauthorized personnel enter the flight 

operations area unexpectedly, flight operations will be terminated immediately.

8) Clear and concise visual observer (VO) training.

9) Integrated safety systems: if the battery runs 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 system capabilities and limitations at all times.

13) Maintain an operational log (integrated automatic flight logs), recording all flights and 

any points 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 calculating its current distance from you and the amount of power needed 

for safe return.

16) Only fly 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 DJI Inspire 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 DJI Inspire 1 User Manual page 28.

29) All flights will be flown only during daylight hours under visual meteorological 

conditions (VMC).

Training is a proven and established means by which to ensure safety of flight 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, we will seek and maintain open lines of communication with any

and all aviation organizations within the area of operations to promote a heightened level of 
awareness 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 be 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 

Dynamic Home Point. Failsafe Return to Home is activated automatically if 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 be 

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 Point. There are three cases that will 

trigger RTH procedure; they are Smart RTH, Low Battery RTH, and Failsafe RTH. Dynamic 

home point is useful in situations when you are in motion and require a Home Point that is 

different from the take-of point. 

In conclusion, we feel there is substantial if not overwhelming evidence indicating that use of 

our unmanned system within the parameters previously discussed and / or outlined provides 

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 approach 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 densely populated area. Taking into 

consideration these criteria in addition to proposed safety precautions, restrictions and 

conditions outlined earlier, it is evident that a sUAS operating without an airworthiness 
certificate 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 DJI 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 controlled 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, Subpart 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 cabin, 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 pilot privileges and limitations: Pilot in Command

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the 

sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent 

level of safety of current operations by requiring the pilot operating the sUAS to have 

completed sUAS flight training by reviewing each of the three DJI Inspire 1 manuals 

(attached to this document), review all DJI Inspire 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 is 

controlled and restricted with all flights planned and coordinated in advance. Subsequently, it 

may be reasonable to assume that the risk 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 operations as 

requested with a pilot who has met the minimum requirements stated above exceeds the 

present level of safety achieved by 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, 

DJI Inspire 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 execute 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 DJI Inspire 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 functioning dual controls. 

Small UAS and remotely piloted aircraft (RPA) do not typically have fully functional 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 functional 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 size 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 less than the minimums mandated, provided the person 
operating 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 typically 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 

will 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

permissions from interested parties (i.e. property owners, local officials) are provided, flight 

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 landing poses 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 powering the Inspire 1 provides approximately 18 minutes of powered flight. 

Consequently, for the DJI Inspire 1 to meet the 30 minute reserve requirement outlined in 14 

CFR §91.151 is impossible. Given the Inspire 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 Lockheed 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 type of risk Section 91.151(a) was intended to address given the size and speed of the 

Inspire 1. Additionally, limiting Inspire 1 flights to 14 minutes or less would significantly

reduce the exemptions 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 anywhere 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 exemptions 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 paragraph (a) of this section or a special flight authorization 

issued under §91.715 is displayed at the cabin or cockpit entrance so that it is 

legible to passengers or crew.

The 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. 91.405(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 because the DJI 

Inspire 1 is very limited in size while carrying a small payload and operating only in restricted 

areas for limited periods of time. Operating at no more than 400’ AGL, if mechanical issues 

arise, the DJI Inspire 1 can be recovered immediately. As 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 preflight the aircraft prior to each flight, perform required maintenance as well as preventive 
maintenance checks and services (PMCS), while maintaining a log of any maintenance 

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 is 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 for 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. In contrast, a sUAS weighing fewer than 

8 lbs. and powered by batteries eliminates virtually 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, weighing 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 commercial 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 concerns 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 national security – provide adequate justification (we feel) for the 

grant of the requested exemptions allowing commercial operation of Cochise Aerial 
Perspective 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://download.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