July 9, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave S.E. 

Washington, D.C. 20590 

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Re: Request for Exemption under Section 333 of the FAA Modernization and Reform Act 

and Part 11 ofthe Federal Aviation Regulations 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 or Madam: 

Pursuant to Section 3 3 3 ofthe FAA Modernization and Reform Act of 2012 (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 Nevada Limited 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 ("F ARs") listed in Appendices A to allow commercial operation of its s UAS, so 

long as such operations are conducted within and under the conditions outlined herein or as 

may be established by the FAA in a grant of this petition. 

Approval of the exemption for petitioner will allow commercial operation of the 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 interest because they clearly satisfy the "Four D's" 

of exemplary uses of sUAS: to replace work that is dangerous, difficult, and at the same time 

provide an equivalent or greater level of safety 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 of battery and maximum payload. Operation of the 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 with helicopters and fixed-wing aircraft that weigh 

thousands of pounds, carry highly flammable fuel, and operate in close proximity to the ground, 

trees, infrastructure, and people. 

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. § 11.3 5, 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-60 1 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 

Information Act, 5 U.S.C. §552(b)(4). 

Copter Kids requests that the publication and comment procedures be waived in accordance with 

14 C.P.R. § 11.87, as the FAA has issued grants of exemption in circumstances similar in all 

material respects to those presented in this petition, and delaying the granting of this 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 affected by the above listed regulations. 

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 of this document, please do not hesitate to contact us at 530.913.1313 or via email at 

copterkidsllc@gmail.com. 

Trent Palmer 

Owner/PIC 

Copter Kids, LLC 

530.913.1313 

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Table of Contents 

I. Publishable Summary ....................................................................................................................... 5 

II. Petitioner's Contact Information ...................................................................................................... 5 

III. Regulations from which the exemption is requested .................................................................................. 6 

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

A. The sUAS ...................................................................................................................... 6 

B. The Crew ......................................................................................................................... 6 

C. Flight Conditions ........................................................................................................... 6 

D. Flight Operations ............................................................................................................. 7 

V. Aircraft and Equivalent Level of Safety ....................................................................................... 7 

VI. Proposed Conditions ofthe Exemption ........................................................................................ 7 

VII. Privacy ................................................................................................................................................ 11 

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

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Exhibit Ljst 

Exhibit 1: Copter Kids, LLC sUAS Motion Picture and Television Operations Manual 

Exhibit 2: Copter Kids, LLC Pilot Qualifications Manual 

Exhibit 3: CK -801 Specifications, Flight Operations and Procedures Manual 

Exhibit 4: CK-802 Specifications, Flight Operations and Procedures Manual 

Exhibit 5: CK-601 Specifications, Flight Operations and Procedures Manual 

Exhibits 1-5 have been submitted confidentially, under separate cover, and are not 

available to the public. 

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I. Publishable Summary 

Pursuant to 14 C.F .R. § 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 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 small unmanned aerial systems (55lbs or 

less) in motion picture and television 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 A TO 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 of sight - 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 s UAS to conduct these operations, weigh 

heavily in favor of granting the exemption. 

II. Petitioner's Contact Information 

Trent Palmer 

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 Exemption Is 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 and purpose-built for safe, reliable operation with a maximum 

weight of under 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 of the sUAS are being submitted confidentially, due to 

the proprietary nature of the sUAS. The petition and the supporting documentation in the Exhibits 

may hereinafter be referred to as the "operating documents." 

The specific conditions of the proposed exemption that relate to the characteristics of the 

sUAS are numbers 1, 5, and 16-20 in Section VI below. Each has been adopted or imposed by the 

FAA in numerous previous grants of Section 333 exemption petitions. 

B. The Crew 

The crew will consist of, at a minimum, a pilot in command (PIC), a visual 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 of the crew are numbers 3 and 6-9 in Section VI below. Each has been adopted or 

imposed by the FAA in numerous previous grants of Section 333 exemption petitions. 

C. Flight Conditions 

The sUAS will be used for scripted closed-set filming for the motion picture 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 stated below under 

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. 

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The flight crew will always make a safety assessment of the risk of every operation, and will only 

operate when it is determined that no hazards are present. 

The specific conditions of the 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 of Section 333 exemption 

petitions. 

D. Flight Operations 

The purpose of every sUAS flight will be to conduct safe, accurate, and efficient closed- set 

filming for the motion picture and television industries. 

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 CK60 1 Specifications, Flight Operations and Procedures Manual provided confidentially under 

separate cover, include detailed policies and procedures for the safe operation and maintenance of 

sUAS included in this petition. 

The specific conditions of the proposed exemption that relate to flight operations are 

numbers 11-12, 17-25, and 32-35 in Section VI below. Each has been accepted or imposed by the 

FAA in numerous previous grants of Section 333 exemption petitions. 

IV. Aircraft and Equivalent Level of Safety 

Petitioner proposes that the exemption apply to s UAS 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 of this petition. 

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 

(proposed Feb. 23, 2015 (to be codified at 14 C.F.R. Parts 21, 43, 45, et al.)). 

V. Proposed Conditions of the Exemption 

1. The sUAS will weigh less than 55 pounds, inclusive of battery and technical payload. 

2. sUAS operations under this exemption will be limited to conducting operations for the 

purpose of closed-set filming for the motion picture and television in Class G 

airspace nationwide. 

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3. Flights will be operated within line of sight of pilot in command (PIC), and a visual observer 

(VO). 

4. Flights will be operated at an altitude of no 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 not be flown at an indicated airspeed exceeding 87 knots (100 mph), and in no 

case will the UA be operated at airspeeds greater than the maximum UA operating airspeed 

recommended by the aircraft manufacturer. 

6. Minimum flight crew for each operation will consist of the sUAS pilot in command (PIC), 

a visual 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 in which the PIC is rated on his or her 

pilot certificate. 

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 of the 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 not perform 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 

operate the camera or other instruments. 

10. The PIC will be designated before the flight and will not be allowed to transfer his or her 

designation for the duration of the flight. The PIC will ensure that the VO can perform the 

functions prescribed in these conditions and the 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 

connection with the operations be present for 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. If the inspection reveals a condition that affects 

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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 and alterations will be properly documented in the aircraft records. 

13. Petitioner will conduct a functional flight test on any sUAS that has undergone maintenance 

or alterations that affect the sUAS operation or flight characteristics, e.g. replacement of a flight 

critical component. The PIC who conducts the functional test flight will make an entry in the 

aircraft records. 

14. The petitioner will carry out its maintenance, inspections, and record keeping requirements, 

at the direction and under the supervision of the sUAS manufacturer. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts will be noted in the aircraft 

records, including total time in service, description of work accomplished, and the signature 

of the manufacturer, authorizing the return of the sUAS to service. The manufacturer will make 

an entry in the aircraft record of the corrective action taken against discrepancies discovered 

between inspections. 

15. When conducting operations for the motion picture and television industry, petitioner will 

submit a written Plan of Activities, and any additional necessary paperwork, to the FSDO at 

least one day before the proposed operations begin. 

16. The sUAS will be operated within visual line of sight (VLOS) of the 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 with 20% battery power remaining. 

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 return to a pre-determined location within the planned operating 

area and land or be recovered in accordance with the 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, rather than flying off uncontrollably or landing at an unknown location. 

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22. 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 in the exemption grant 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. If it updates or 

revises its operating documents, it will present updated and revised documents to the 

Administrator upon request. If the 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 grant of exemption. 

23. Petitioner will obtain written and/or oral permission from the landowners/authorized agents 

of the landowners over which flights will be 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 conducted under special visual flight rules (SVFR). 

26. The petitioner will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under the grant of exemption. 

Petitioner will request a Notice to Airman (NOT AM) not more 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 in the ATO issued COA, including class of airspace, altitude level 

and potential transponder requirements. 

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 of agreement with that 

airport's management has been obtained, and the operation is conducted in accordance 

with a NOT AM as required by the operator's COA. Any letter of agreement with the airport 

management will be made available to the Administrator upon request. 

28. The sUAS will not be operated less than 500 feet below, or less than 2,000 feet 

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

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 CFR part 47, and have identification (N-Number) markings 

in accordance with 14 CFR part 45, Subpart C. Markings will be 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 government oversight agency requirements. 

32. The sUAS will remain clear and yield the right of way to all manned aviation operations 

and activities at all times. 

33. The sUAS will not be operated by the PIC from any moving device or vehicle. 

34. The sUAS will not be operated over congested or densely populated areas. 

35. Petitioner will conduct all flight operations at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless one of the following three 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 of the sUAS, the 

PIC will ensure that flight 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 of the risk of operating closer to those objects and determined that it does not 

present an undue hazard. 

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an 

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

36. Petitioner will report any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the 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 concern that the proposed flights will cause invasions of privacy because all 

flights will occur (i) over public spaces, where there is no expectation of privacy, 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 present during filming. 

VII. Public Interest 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 

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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 

exemption is in the public interest. 

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 more than adequate 

justification for the grant of the requested exemption allowing commercial operation of 

applicant's sUAS for filming the television and movie industry and the construction 

industry, pursuant to petitioner's rules of operation. 

A. Motion Picture and Television Industry Filming 

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 of safety 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 in this petition, many of these dangerous conditions 

will be alleviated. The included sUAS weigh less than approximately 36 lbs, including 

maximum payload. The pilot and flight crew will be safely on the ground rather than several 

hundred feet in the air. The sUAS is powered by a battery, and requires 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 and television industry. 

Exemption No. 11062 

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