July 9, 2015 U.S. DepartmentofTransportation DocketManagement System 1200NewJerseyAve S.E. Washington, D.C. 20590 

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Re: Requestfor Exemptionunder Section 333 ofthe FAAModernization andReformAct andPart 11 oftheFederalAviationRegulations from 14 C.P.R. 61.23(a) and (c); 61.101(e)(4) and (5); 61.113(a); 61.315(a); 91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(l); 91.409(a)(1) and (2); 91.417(a) & (b). Dear Sir orMadam: Pursuant to Section 3 3 3 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.P.R. Part 11, Copter Kids, LLC files this petition for exemption on behalf of Copter Kids, LLC, a NevadaLimited Liability Company ("Copter Kids"), an operator of Small Unmanned Aircraft ("sUAS") used for closed-set filming for the motion picture and television industries. Specifically, applicant seeks an exemption from the Federal Aviation Regulations ("FARs") listed in Appendices A to allow commercial operation ofits sUAS, so long as such operations are conducted within and under the conditions outlinedherein or as may be establishedbythe FAAin a grantofthispetition. Approval ofthe exemption for petitioner will allow commercial operation ofthe CK-801 Coaxial Octocopter, the CK-802 Coaxial Octocopter and CK-601 Hexacopter for scripted closedset filming for the motion picture and television industries in Class G airspace nationwide, or as otherwise prescribed in an Air Traffic Organization ("ATO") issued COA. The sUAS operations contemplated by this petition are in the public interestbecausethey clearly satisfy the "Four D's" ofexemplary uses of sUAS: to replace work that is dangerous, difficult, and at the same time provide an equivalent or greater level ofsafety than alternative manned aircraft operations. The sUAS covered by this petition are small battery-powered craft, weighing up to approximately 36 lbs. (16.3 kg.), inclusive ofbattery and maximum payload. Operation ofthe sUAS under the strict conditions proposed below will provide an equivalent level of safety, as Congress intended, while still allowing commercial operations. Operations using this sUAS are far safer than conventional operations conducted withhelicopters and fixed-wing aircraft thatweigh thousands ofpounds, carry highly flammable fuel, and operate in close proximity to the ground, trees, infrastructure, andpeople. Congress directed the FAA to consider seven factors in deciding whether to approve Section 333 exemption petitions

- size, weight, speed, operational capability, proximity to

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airports, proximity to populated areas, and operation within visual line of sight. In this case, each factor supports the exemption request. In particular, the sUAS is small, and will operate at slow speeds and close to the ground. It will be able to more safely and efficiently film over closed sets. The substantial increase of safety and decrease of risk to human life and to property weighs heavily in favor of granting the exemption. Pursuant to 14 C.F.R. §11.35, petitioner requests confidential treatment for certain information provided with this request for exemption. Specifically, petitioner is submitting its proprietary sUAS Motion Picture and Television Operations Manual; Pilot Qualifications Manual; CK-801 Specifications, Flight Operations and Procedures Manual; CK-802 Specifications, Flight Operations and Procedures Manual; and CK-601 Specifications, Flight Operations and Procedures Manual under separate cover as Exhibits 1-5. It requests that the information contained in those exhibits not be made public because they are trade secrets whose disclosure would harm petitioner. They contain valuable commercial data that is not publically available and are protected from release under the Freedom of InformationAct, 5 U.S.C. §552(b)(4). Copter Kids requests thatthe publication and commentprocedures be waived in accordance with 14 C.P.R. § 11.87, as the FAA has issued grants ofexemption in circumstances similar in all material respects to those presented in this petition, and delaying the granting ofthis petition would adversely affect the public, the FAA, and Copter Kids. The public, as well as the FAA, would be better served by the FAA quickly granting this petition and thereby freeing up limited FAA resources and allowing FAA inspectors to dedicate their time and attention to other priorities. Moreover, Copter Kids is eagerly seeking to start commercial operations and is adversely affectedbythe above listedregulations. For your ease in reviewing this petition, please refer to the table of contents which begins on page 3. If we can provide any additional information to assist your understanding or review ofthis document, please do not hesitate to contact us at 530.913.1313 or via email at copterkidsllc@gmail.com.

TrentPalmer Owner/PIC CopterKids, LLC 530.913.1313

2Table ofContents I. Publishable Summary
.......................................................................................................................5 II. Petitioner's ContactInformation

...................................................................................................... 5 III. Regulations fromwhichthe exemptionisrequested

.................................................................................. 6 IV. Proposed Operations

........................................................................................................................... 6 A. The sUAS
...................................................................................................................... 6 B. The Crew
......................................................................................................................... 6 C. FlightConditions

........................................................................................................... 6 D. Flight Operations

............................................................................................................. 7 V. Aircraft andEquivalentLevel ofSafety

.......................................................................................7 VI. Proposed Conditions oftheExemption

........................................................................................7 VII. Privacy

................................................................................................................................................ 11 VIII. Public Interest and Safety

.............................................................................................................. 11

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# )f(KIDS ExhibitLjst Exhibit 1: Copter Kids, LLC sUAS MotionPicture andTelevision Operations Manual Exhibit2: Copter Kids, LLC Pilot Qualifications Manual Exhibit3: CK-801 Specifications, FlightOperations andProceduresManual Exhibit4: CK-802 Specifications, FlightOperations andProceduresManual Exhibit5: CK-601 Specifications, FlightOperations andProceduresManual

Exhibits 1-5 have been submitted confidentially, under separate cover, and are not availableto the public.

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# )f(KIDS I. Publishable Summary Pursuant to 14 C.F.R. § 11, the following summary is provided for publication in the Federal Register, should itbe determinedthatpublicationis needed: Applicant seeks an exemptionfrom the following rules: 14 CPR§§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) to operate commercially smallunmanned aerial systems (55lbs or less) inmotionpicture andtelevision operations. Approval of the exemption for petitioner will allow commercial operation of the CK-801, CK-802 and CK-601 sUAS, all propriety in design, for scripted closed-set filming for the motion picture and television industries, or as otherwise prescribed in an ATO issued COA. The requested exemption should be granted because operation of small sUAS, weighing approximately 36 lbs. (16.3 kg.), inclusive of battery and maximum payload, conducted in the strict conditions outlined below, will provide an equivalent level of safety, while still allowing commercial operations. The lightweight aircraft covered by the exemption are far safer than conventional operations conducted with helicopters and fixed-wing aircraft weighing thousands of pounds and carrying highly flammable fuel, and operating in close proximity to the ground, power lines, transmission towers, pipelines, and people. The seven factors Congress directed the FAA to consider when approving Section 333 exemption petitions

- size, weight, speed, operational capability, proximity to airports, proximity to populated areas, and operation within visual line ofsight

- each support the request. In particular, the aircraft are small, and will operate at slow speeds, and close to the ground in order to more safely and efficiently conduct inspections that would otherwise involve a risk of death to the inspectors. The substantial increase of safety and decrease of risk to human life, coupled with the low risk use of sUAS to conduct these operations, weigh heavily in favor ofgrantingthe exemption. II. Petitioner's ContactInformation TrentPalmer Copter Kids, LLC 2295 Pea vine Valley Rd. Reno, NV 89523 530.913.1313 copterkidsllc@gmail.com

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III. Regulations From Which The ExemptionIs Requested 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(l), 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2), and 91.417(a) and (b). IV. Proposed Operations A. ThesUAS The requested exemption will permit petitioner to operate the CK-801, CK-802 and CK601 sUAS, all propriety in design andpurpose-builtfor safe, reliable operationwith a maximum weight ofunder approximately 36 lbs. (16.3 kg.), inclusive of batteries and maximum payload. These rotorcraft have the capability to hover and move in the vertical and horizontal planes simultaneously. Please refer to Exhibits 3-5 for further technical information regarding the sUAS. Details regarding the design and assembly ofthe sUAS are being submitted confidentially, due to the proprietary nature ofthe sUAS. The petition and the supporting documentation in the Exhibits may hereinafterbe referredto as the "operating documents." The specific conditions ofthe proposed exemption that relate to the characteristics ofthe sUAS are numbers 1, 5, and 16-20 in SectionVI below. Eachhas been adopted or imposed bythe FAA innumerous previous grants ofSection333 exemptionpetitions. B. The Crew The crewwill consist of, at aminimum, apilotincommand (PIC), avisual observer (VO). Specific PIC and VO qualifications and training are outlined in Exhibits 1 and 2, Copter Kids, LLC sUAS Motion Picture and Television Operations Manual and Copter Kids, LLC Pilot Qualifications Manual, provided confidentially under separate cover. The specific conditions of the proposed exemption that relate to the training and characteristics ofthe crew are numbers 3 and 6-9 in SectionVI below. Each has been adopted or imposedbythe FAAinnumerousprevious grants ofSection 333 exemptionpetitions. C. Flight Conditions The sUAS will be used for scripted closed-set filming for the motionpicture and television industries. It will be flown in Class G airspace nationwide under 400 feet above ground level ("AGL") and under controlled conditions over property that is restricted as statedbelowunder D. Flight Operations. Petitioner will work with the local FSDO when planning operations. Petitioner will only operate its sUAS in visual meteorological conditions (VMC). The sUAS will at all times be no less than 500 feet below and no less than 2,000 feet horizontally from a cloud, and petitioner will not conduct operations unless visibility is at least 3 statute miles from the PIC. 6

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The flight crew will always make a safety assessment ofthe risk ofevery operation, and will only operate whenitis determinedthatno hazards are present. The specific conditions ofthe proposed exemption that relate to the flight conditions in which the sUAS will be operated are numbers 2, 4, 16, and 28-29 in Section VI below. Each has been adopted or imposed by the FAA in numerous previous grants ofSection 333 exemption petitions. D. Flight Operations Thepurpose ofevery sUAS flight will beto conduct safe, accurate, and efficientclosed- set filming for the motionpicture and televisionindustries. Exhibits 1-5, Copter Kids, LLC sUAS Motion Picture and Television Operations Manual; Copter Kids, LLC Pilot Qualifications Manual; CK-801 Specifications, Flight Operations and Procedures Manual; CK-802 Specifications, Flight Operations and Procedures Manual; and CK601 Specifications, Flight Operations and Procedures Manual provided confidentially under separate cover, include detailed policies andprocedures for the safe operation and maintenance of sUAS includedinthispetition. The specific conditions of the proposed exemption that relate to flight operations are numbers 11-12, 17-25, and 32-35 in SectionVI below. Eachhas been accepted or imposedbythe FAAinnumerousprevious grants ofSection 333 exemptionpetitions. IV. Aircraft and EquivalentLevel ofSafety Petitioner proposes that the exemption apply to sUAS that have the characteristics and that operate with the limitations proposed herein. These limitations provide for a level of safety at least equivalent to or higher than manned aircraft operations under the current regulatory structure. Section VI below, together with operating documents, identifies the limitations and conditions to which petitioner agrees to be bound when conducting commercial operations under a grant ofthispetition. Approval of the commercial operations outlined in this petition presents no national security issue. The PIC is willing to undergo a background check, including the proposed Transportation Security Administration Vetting process, to ensure that no national security threat is present. Operation and Certification of Small Unmanned Aircraft, 80 Fed. Reg. 9543 at 9572 (proposedFeb. 23, 2015 (to be codified at 14 C.F.R. Parts 21, 43, 45, etal.)). V. Proposed Conditions ofthe Exemption 1. The sUAS will weighless than 55 pounds, inclusive ofbattery andtechnicalpayload. 2. sUAS operations under this exemption will be limited to conducting operations for the purpose ofclosed-set filming for the motion picture and television in Class G airspace nationwide. 7

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3. Flights will be operatedwithin line ofsight ofpilotin command (PIC), and a visual observer (VO). 4. Flights will be operated at an altitude ofno more than 400 feet AGL, as indicated by the procedures specified in the operating documents. All altitudes reported to ATC must be in feetAGL. 5. The sUAS will notbe flown at an indicated airspeed exceeding 87 knots (100 mph), and inno case will the UAbe operated at airspeeds greaterthanthe maximumUA operating airspeed recommendedbythe aircraftmanufacturer. 6. Minimum flight crew for each operation will consist ofthe sUAS pilot in command (PIC), avisual observer (VO). 7. PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal Government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft inwhichthe PIC is rated onhis orher pilotcertificate. 8. The petitioner will not permit any PIC to operate unless the PIC meets its qualification criteria as outlined in its Pilot Qualification Manual and demonstrates the ability to safely operate the sUAS in a manner consistent with how the sUAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). A record ofthe PIC training will be documented and made available upon request by the Administrator. Training operations will only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations will be considered nonparticipants, and the PIC will operate the sUAS with appropriate distance from nonparticipants in accordance with 14 CFR §91.119. 9. The VO will notperform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions, and will not be permitted to operatethe cameraor otherinstruments. 10. The PIC will be designated before the flight and will not be allowed to transfer his or her designation for the duration ofthe flight. The PIC will ensure that the VO can perform the functions prescribedinthese conditions andthe operating documents. 11. A briefing will be conducted in regard to the planned sUAS operations prior to each day's activities. It will be mandatory that all personnel who will be performing duties in connectionwiththe operationsbepresentfor this briefing. 12. Prior to each flight, the PIC will inspect the sUAS, including the Ground Control Station, to ensure it is in a condition for safe flight. Ifthe inspection reveals a condition that affects 8

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the safe operation of the sUAS, the PIC will not operate the sUAS until the necessary maintenance has been performed and the sUAS is found to be in a condition for safe flight. All maintenance andalterations will be properly documentedinthe aircraftrecords. 13. Petitioner will conduct a functional flight test on any sUAS that has undergone maintenance or alterations thataffectthe sUAS operation orflight characteristics, e.g. replacement ofaflight critical component. The PIC who conducts the functional test flight will make an entry in the aircraftrecords. 14. The petitioner will carry out its maintenance, inspections, and record keeping requirements, at the direction and under the supervision ofthe sUAS manufacturer. Maintenance, inspection, alterations, and status ofreplacement/overhaul component parts will be noted in the aircraft records, including total time in service, description ofwork accomplished, and the signature ofthe manufacturer, authorizingthe return ofthe sUAS to service. The manufacturer will make an entry in the aircraft record ofthe corrective action taken against discrepancies discovered betweeninspections. 15. When conducting operations for the motion picture and television industry, petitioner will submit a written Plan ofActivities, and any additional necessary paperwork, to the FSDO at least one daybeforethe proposed operationsbegin. 16. The sUAS will be operated within visual line ofsight (VLOS) ofthe PIC and VO at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses. PIC and VO will at all times be able to communicate verbally. They will not be permitted to use electronic messaging or texting to communicate during flight operations. 1

7. The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the sUAS with20%batterypowerremaining. 18. Actual total flight time for each operational flight will result in no less than a 20% battery reserve. 19. The sUAS will have the capability to abort a flight m case of unexpected obstacles or emergencies. 20. The sUAS will be programmed so that if it loses communication with the ground station or loses its GPS signal, it will returnto a pre-determined location withinthe planned operating area and land orberecovered in accordance withthe operating documents 21. If the sUAS and its radio control link disconnect during flight, the system's failsafe protection will be triggered and the multi-rotor will return to home and land automatically, ratherthan flying offuncontrollably orlanding at anunknown location.

922. The operating documents required under 14 CFR §§ 91.9 and 91.203 will be maintained and available to the PIC at the Ground Control Station of the sUAS any time the sUAS is operating. These documents will be made available to the Administrator or any law enforcement official upon request. If a discrepancy exists between the conditions and limitations inthe exemptiongrant and the procedures outlined in the operating documents, the grant conditions and limitations will take precedence and will be followed. Otherwise, the petitioner will follow the procedures outlined in its operating documents. Ifit updates or revises its operating documents, it will present updated and revised documents to the Administrator upon request. Ifthe petitioner determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the Petitioner will petition for an amendment to the grantofexemption. 23. Petitioner will obtain written and/or oral permission from the landowners/authorized agents ofthe landowners overwhichflights willbe conducted. 24. Petitioner will obtain all required permissions and permits from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agenc1es. 25. sUAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations will be conducted under visual meteorological conditions (VMC). Flights will not be conductedunder specialvisualflightrules (SVFR). 26. The petitioner will obtain an Air Traffic Organization (ATO) issued Certificate ofWaiver or Authorization (COA) prior to conducting any operations under the grant ofexemption. Petitioner will request a Notice to Airman (NOTAM) notmore than 72 hours in advance, but not less than 48 hours prior to the operation. All operations will be conducted in accordance with airspace requirements inthe ATO issued COA, including class ofairspace, altitude level andpotentialtransponderrequirements. 27. The sUAS will not be operated within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical chart unless a letter ofagreement with that airport's management has been obtained, and the operation is conducted in accordance with aNOT AM as requiredby the operator's COA. Any letter ofagreementwiththe airport managementwillbemade availableto the Administratoruponrequest. 28. The sUAS will not be operated less than 500 feet below, or less than 2,000 feet horizontally from, a cloudorwhenvisibilityis lessthan 3 statute miles fromthe PIC. 29. All operations shall be conducted in Class G airspace or as otherwise prescribed in an ATO issued COA. 30. All aircraft operated in accordance with this exemption will be identified by serial number, registered in accordance with 14 CFRpart 47, and have identification (N-Number) markings in accordance with 14 CFRpart45, Subpart C. Markings willbe as large as practicable.

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31. Before conducting operations, petitioner will ensure that the radio frequency spectrum used for operation and control of the sUAS complies with the Federal Communications Commission (FCC) or other appropriate governmentoversightagencyrequirements. 32. The sUAS will remain clear and yield the right ofway to all manned aviation operations and activities at all times. 33. The sUAS will notbe operatedbythe PIC from anymoving device orvehicle. 34. The sUAS will notbe operated over congested ordenselypopulated areas. 35. Petitioner will conduct all flight operations at least 500 feet from all nonparticipating persons, vessels, vehicles, and structuresunless one ofthe followingthree conditions is met:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the sUAS and/or debris in the event of an accident. The petitioner will ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe sUAS, the PIC will ensurethatflight operations cease immediately. b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closer to those objects and determined that it does not presentanunduehazard.

c. Operations nearer to the PIC, VO, operatortrainees or essential persons do notpresent an undue hazardto those personsper § 91.119(a). 36. Petitioner will report any incident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe operational area as defined by the applicable COA to the FAA's UAS Integration Office (AFS-80) within 24 hours. Petitioner will report accidents to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. VI. Privacy There is little concernthatthe proposed flights will cause invasions ofprivacy because all flights will occur (i) over public spaces, where there is no expectation ofprivacy, and around participating individuals or (ii) over private, restricted property where applicant has permission from the landowner/authorized agent to film. When the sUAS is being flown, the onboard cameras will be focused on the film or inspection area, not on nonparticipating individuals who may be presentduring filming. VII. PublicInterest and Safety The planned sUAS use will increase ground safety in both the television and movie industry. The enhanced safety and reduced environmental impact achieved using a sUAS 11

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with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the sUAS operation enabled by this exemptionis inthepublic interest. Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of 2012

- size, weight, speed, operating capabilities, proximityto airports and populated areas and operationwithinvisual line ofsight andnational security

- providemore than adequate justificationfor the grant ofthe requested exemption allowing commercial operation of applicant's sUAS for filming the television and movie industry and the construction industry, pursuantto petitioner's rules ofoperation. A. Motion Picture andTelevisionIndustryFilming As the FAA has repeatedly recognized in granting other exemptions under Section 333, the use of a sUAS to take videos and photography over closed, scripted, motion picture and television sets significantly increases the level ofsafety for both the actors and crew. Currently, filmmakers use manned aircraft, which can weigh 6,000 lbs. or more. Manned aircraft also, by definition, carry a pilot and other crew. They carry flammable fluids, and require large areas to take off, operate over, and land. By using the sUAS described inthispetition, many of these dangerous conditions will be alleviated. Theincluded sUAS weighless than approximately 36 lbs, including maximumpayload. The pilot and flight crew will be safely on the groundrather than several hundred feet inthe air. The sUAS is poweredby abattery, andrequires a small area to operate in. The FAA has previously determined that using a sUAS such as these will provide a greater level of safety when filming for the motion picture andtelevision industry. ExemptionNo. 11062

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