TOBIN R. COOLEY Petition for Exemption pg. 1

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPROTATION

FEDEAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No._______________

IN THE MATTER OF THE PETTITION FOR EXEMPTION OFF:

SIERRA STUDIOS PHOTOGRAPHY

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL

OPERATION OF CHERSON CX-20 PATHFINDER MICRO UNMANNED

AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on July 26, 2015

Tobin R. Cooley

8000 Offenhauser Dr. #28D

Reno, Nevada 89511
TOBIN R. COOLEY Petition for Exemption pg. 2

TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS 3

SUMMARY 4

INTERSTS OF PETTIONER 4

BACKGROUND 4

BASIS FOR PETTION 5

NAME AND ADRESS OF PETTIONER 6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH SSP SEEKS 

EXEMPTION 6

THE EXTENT OF RELIEF TOBIN R. COOLEY SEEKS AND THE REASONS FOR THAT

RELIEF 13

THE REASONS WHY GRANTING TOBIN R. COOLEY’S REQUEST WOULD BE IN THE 

PUBLIC INTEREST 15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY 16

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISER 25

ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS ABAILABLE 

TO SUPPORT TOIBN R. COOLEY’S REQUEST 25

CONCLUSION 25

APPENDICES 27
TOBIN R. COOLEY Petition for Exemption pg. 3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AMA Aeronautical Modeling Academy

AOI Area of Interest

ATC Air Traffic Control

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot in Command

SECTION 333 FAA Modernization and Reform Act of 2012 (FMRA) Sec. 333

SO Safety Observer

SOP Standard Operating Procedures

UAS Unmanned Aircraft System

mUAS Micro Unmanned Aircraft System (pursuant Section 333)

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
TOBIN R. COOLEY Petition for Exemption pg. 4

SUMMARY

Tobin R. Cooley seeks exemption from the requirements of 14 C.F.R. §§ 61.113(a) & (b) or 

alternatively an exemption from C.F.R §§ 61.113, 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(

1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant 

to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit 

SSP to operate an Micro Unmanned Aircraft System (mUAS) for the commercial purpose of conducting

aerial video and photography of constructions sites, real estate, landscape and numerous types of 

inspections i.e. roof tops, chimney stacks etc... over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Tobin R. Cooley is a skilled (mUAS) pilot, placing 3

rd all around of 12 competitors at the 1st

annual 2014 Drone Zone event at the Reno National Air Races, and is a current member of the 

Aeronautical Modeling Academy (AMA). Experience in videography and photography spans 30 years as 

both a hobbyist and professional and recently has added aerial videography and photography to his 

resume, this new technology brings new dimension and added appeal to skills that have been honed over 

the years. Aerial services to be implemented upon FAA approval will vary, Tobin R. Cooley will provide 

a broad spectrum of services utilizing the safe operation and high definition imaging from current mUAS.

The following list of services are a sample (but not limited to), of known markets SSP will be targeting:

 Advertising – auto lots, architecture, corporate headquarters...

 Agriculture – infrared imaging, mapping, periodic crop inspection...

 Construction industry – landscaping, custom homes, housing developments, industrial...

 Film

 Mapping

 Real estate marketing

 Residential – appraisals, roof, chimney & gutter inspections...

MICRO UNMANNED AIRCRAFT SYSTEM (mUAS)

Cheerson CX-20 Auto Pathfinder, Micro Unmanned Aircraft System

Tobin R. Cooley seeks an exemption to operate Cheerson CX-20 Auto Pathfinder system for 

compensation or hire within the NAS. The Cheerson CX-20 Auto Pathfinder is constructed of frangible

materials and is a VTOL (vertical takeoff and landing) mUAS (micro unmanned aircraft system) with a 

GCS (ground control station) that uses a 2.4G (open frequency) transmitter. The Cheerson CX-20 has a 

maximum gross weight of approximately 2.5 pounds when fully equipped with battery, propellers, 

propeller guards, Walkera 2D gimbal and Gopro Hero 3+ camera, the dimensions with propeller guards 

on are 20 3⁄4” wide by 20 3⁄4” long and stands 8” tall to the top of GPS tower. The CX-20 has an 

approximate maximum speed of 30 knots, and an approximate transmitter distance of 300 meters (984.25 

feet), a Lithium Polymer battery (11.7v) drives the electric brushless motors of the four main rotors and 

the CX-20 is equipped with autonomous fail safes in the event of LOL (loss of link) that prevent fly offs 

or crashes.

The Cheerson CX-20 Auto Pathfinder that will be operated by Tobin R. Cooley will be registered 

in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R. Part 47, Aircraft 

Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking.
TOBIN R. COOLEY Petition for Exemption pg. 5

BASIS FOR PETITION

Petitioner, Tobin R. Cooley, pursuant to the provisions of the Federal Aviation Regulations (14 

C.F.R. § 11.16) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special 

Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially 

operate the Cheerson CX-20 Auto Pathfinder in the NAS (National Airspace System), and for an 

exemption from the requirements of 14 C.F.R. §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, Tobin R. Cooley operation of the Cheerson CX-20 Auto Pathfinder 

mUAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, Tobin R. Cooley requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) 

& (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to 

aircraft with an airworthiness certificate.

Tobin R. Cooley submits that the requested relief is proper since an equivalent level of safety will 

be ensured. Tobin R. Cooley will conduct thorough pre-flight inspections and use experienced personnel 

or technicians to perform regular maintenance, alterations, or preventive maintenance on the mUAS using 

the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance 

Log, and as per Cheerson CX-20 Auto Pathfinder instruction manual). Furthermore, Tobin R. Cooley will 

document and maintain all maintenance records for the Cheerson CX-20 Auto Pathfinder mUAS.

Relief from certain requirements of Section 61.113(a) & (b), entitled Private pilot privileges and 

limitations: Pilot in command, is requested by Tobin R. Cooley to the extent necessary to allow a PIC 

(Pilot in Command) is able to safely operate the Cheerson CX-20 Auto Pathfinder mUAS in a manner 

consistent with tis exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. Alternatively, Tobin R. Cooley request that the 

requirement of private pilot licensing for commercial UA use required of previous exemptions be lifted in 

this particular request pursuant to Tobin R. Cooley’s argument herein.

Tobin R. Cooley seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because 

the Cheerson CX-20 Auto Pathfinder mUAS does not require an airworthiness certificate in accordance 

with 14 CF.R. Part 21, Subpart H. As such, Tobin R. Cooley submits that he will ensure that the Cheerson 

CX-20 Auto Pathfinder is in an airworthy condition, prior to every flight, by determining that the mUAS 

is in compliance with the operating documents (i.e., Monthly Maintenance Log, and the Cheerson CX-20 

Auto Pathfinder instruction Manual), and that the aircraft is in a condition for safe flight.

Tobin R. Cooley also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the Cheerson CX-20 Auto Pathfinder mUAS does not have a typical barometric 

altimeter onboard. However, altitude information of the Cheerson CX-20 Auto Pathfinder will be 

provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry 

data link, which downlinks from the mUAS to the GCS for active monitoring of the flight path. This 

information, combined with Tobin R. Cooley’s operation of the Cheerson CX-20 Auto Pathfinder mUAS 

within VLOS (visual line of sight), at or below 400 feet AGL, will ensure a level of safety equivalent to 

Section 91.121.

Additionally, Tobin R. Cooley seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. Tobin R. Cooley submits that safety will not be 
TOBIN R. COOLEY Petition for Exemption pg. 6

affected by operation of the Cheerson CX-20 Auto Pathfinder mUAS during daylight hours in VMC 

under VFR, with enough battery power to fly for a total duration of approximately 10 minutes to the first 

point of intended landing, assuming normal cruising speed, to fly after that for at least 2 minutes.

In accordance with 14 C.F.R. § 11.81, Tobin R. Cooley provides the following information in 

support of his petition for exemption:

A. NAME AND ADDRESS OF THE PETITIONER.

The name and address of the Petitioner and point of contact are:

Tobin R. Cooley

8000 Offenhauser Drive, #28D

Reno, Nevada 89511

Phone: (775) 379-7168

Email: cooleytl@gmail.com

B. THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH Tobin R. Cooley SEEKS 

EXEMPTION.

1. Tobin R. Cooley SEEKS EXEMPTION FROM THE REQUIREMETS OF SECTON 

61.113.

TOBIN R. COOLEY’S ARGUMENT FOR EXEMPTON FROM 14 C.F.R § 61.113: 

PRIVATE PILOT PRIVILEGES AND LIMITATIONS: PIC.

Tobin R. Cooley requests an exemption from 14 C.F.R. § 61.113 so that the PIC of the mUAS 

will not be required to possess a private or commercial pilot’s license. As the FAA and numerous other 

national airspace regulators have recognized, UA operations conducted by persons who do not hold a 

pilot’s license can still achieve the equivalent level of safety of current operations by manned aircraft with 

pilot’s having a private or commercial pilot’s license.

Although it recognizes that a pilot’s license is unnecessary for safe UA operation, the FAA has to 

date declined to allow grant exemptions under Section 333 that would permit individuals who possess 

neither a private nor a commercial pilot’s certificate to conduct commercial UA operations. It has 

specified two reasons for declining to do so. First, it has stated that it does not possess the authority under 

Section 333 to exempt individuals from the requirement under 49 U.S.C. §44711 to hold an airman 

certificate authorizing the airman to serve in the capacity for which the certificate was issued. Exemption 

No. 11110 at 14. Second, the FAA has concluded that the Department of Homeland Security (DHS) 

security screening required of all certified airmen meets the statutory requirement in Section 333 the 

operations not pose a threat to national security. Exemption No. 11110 at 15.

Tobin R. Cooley respectfully request that the FAA reconsider its position. There is no dispute that 

it is unnecessary for an operator of a mUAS to go through the rigorous process of becoming a certified 

pilot in order to safely operate a mUAS. In addition, the FAA does have the authority to exempt mUAS 

operators from the requirement in 49 U.S.C. §44711 to hold an airman certificate for “serv[ing] in the 

capacity for which the certificate was issued.” Indeed, it has exercised that authority repeatedly in the 

Section 333 process. Finally, the FAA’s security concerns can be addressed by a variety of methods 

involving operator background checks to be conducted by government agencies.
TOBIN R. COOLEY Petition for Exemption pg. 7

2. THE FAA AND FOREIGN REGULATORS RECOGNIZE THAT OBTAINING A 

MANED AIRCRAFT PIOT LICENSE IS UNNECESSARY FOR SAFE OPERATION OF A 

mUAS

The FAA, like the other national airspace regulators that have considered the issue, has concluded 

that mUAS operations conducted by persons who do not hold a pilot’s license can still achieve the 

equivalent level of safety of current operations by manned aircraft with pilots holding a private or 

commercial pilot’s license. In its recent UAS NPRM, the FAA stated:

“While these airman certification requirements are necessary for manned aircraft operations, they 

impose an unnecessary burden for many UAS operations. This is because a person typically 

obtains a private or commercial pilot certificate by learning how to operate a manned aircraft. 

Much of that knowledge would not be applicable to small UAS operations because a small UAS 

is operated differently than manned aircraft. In addition, the knowledge currently necessary to 

obtain a private or commercial pilot certificate would not equip the certificate holder with the 

tools necessary to safely operate a small UAS... Thus, requiring persons wishing to operate a 

small UAS to obtain a private or commercial pilot certificate imposes the cost of certification on 

those persons, but does not result in a significant safety benefit because the process of obtaining 

the certificate does not equip those persons with the tools necessary to mitigate the public risk 

posed by small UAS operations.” Operation and Certification of Small Unmanned Aircraft, 80 

Fed. Reg. 9543 at 9550 (proposed Feb. 23, 2015 (to be codified at 14 C.F.R. Parts 21, 43, 45, et 

al.)).

The FAA’s conclusion that manned aircraft flying experience is unnecessary for the operation of 

a UA is supported by research by the FAA and the Army Research Laboratory. They demonstrate that 

UAs, even those much larger than the mUAS proposed by Tobin R. Cooley, can be safely flown by noncertificated pilots with a small amount of training. For example, one Army Research Laboratory study

concluded:

“[T]he specific moto skills needed to control the radio-controlled UAV would have to be learned 

by aviators independently of the motor skills learned in flying an aircraft. In particular, the 

somatic and visual cues that pilots use during aircraft landings would not be useful (and perhaps 

even counter-productive) for the different skill sets and perceptual viewpoint necessary for radiocontrolled landings.”1

Additional research reports lend further support for the exclusion requested. For example, a report 

sponsored by the FAA concluded that “We know that certain system, like the U.S. Army Hunter and 

Shadow systems, are successfully flown by pilots with no manned aircraft experience.”2

In addition, foreign government airspace regulators that have examined the issue have 

consistently recognized that the skills required to fly a manned aircraft are irrelevant to operating a UA. 

For that reason, they have concluded that UA operators do not need to have a private or commercial 

pilot’s license. Canada, for example, does not require a pilot’s license to operate a UA. Transport Canada 

requires training of UA operators, but that training is limited to pilot ground school and flight operation 

training on UAs, not manned aircraft.3 Moreover, Canada allows this training to be “provided by other 

pilots, manufacturers, [UA] flight training organizations or ... self-taught.”4

1 Michael J. Barnes, Beverly G. Knapp, Barry W. Tillman, Brett A Walters & Darlene Veliki,

Crew systems analysis of unmanned aerial vehicle (UAV) future job and tasking environments, Technical 

Report ARL-TR-2081, Aberdeen Proving Ground, MD: Army Research Laboratory, page 12 (2000), 

available at http://www.dtic.mil/dtic/tr/fulltext/u2/a374230.pdf. 
TOBIN R. COOLEY Petition for Exemption pg. 8

2 Kevin W. Williams, Unmanned Aircraft Pilot Medical Certification Requirements, Report 

DOT/FAA/AM-07/3, FAA Civil Aerospace Medical Institute, page 2, (2007), available at 

http://fas.org/irp/program/collect/ua-pilot.pdf. While the authors speculated that UAS use in populated 

areas may change this assessment, indication further research was needed to address this concern, this 

concern is inapplicable as Helios’s flights will not be in congested areas. See also Jason S. McCarley & 

Christopher D. Wickens, Human Factors Implications of UAVs in the National Airspace, Institute of 

Aviation, Aviation Human Factors Division, University of Illinois at Urbana-Champaign, 13 (2004), 

available at http://www.tc.faa.gov/logistics/grants/pdf/2004/04-G-032.pdf. 

3

See Civil Aviation, Standards, Transport Canada, Advisory Circular: Guidance Material for Operating 

Unmanned Air Vehicle Systems under an Exemption at 14 and 18-22, (Nov. 27, 2014) available at

http://www.tc.gc.ca/media/documents/ca-opssvs/ac-600-004.pdf.

4

Id. at 14.

Similarly, the United Kingdom’s Civil Aviation Authority (CAA) recognized that determining 

“Remote Pilot qualification requirements on the same basis as manned aircraft may yield requirements 

that are too inflexible, too onerous and inappropriate for UAS operations.”5 As a result, the CAA only 

requires UA operators to demonstrate UA operator competence.6 While there are a variety of ways to 

demonstrate competence, the most common is to complete a course that will lead to a ground exam and 

flight test. Australia, too, requires only passage of a UA-specific ground school program in lieu of a 

private pilot license.7Finally, more than a dozen countries, including Germany, Italy, France, Spain and 

the Netherlands, have adopted the National UAS Certificate for Small Unmanned Aircraft (BNUC-S) 

Standard for UA pilot certification.7 This standard results in a type-specific UA certificate and does not 

require the operator to have a pilot’s license. The process involves taking a short ground school course, 

passing a ground school test and then passing a practical test on commercial operation of the specific 

UAS per the UAS manufacturer’s operations manual.

All of this experience and evidence indicates that the proposed exemption will provide a greater 

level of safety than operations under 14 C.F.R. §61.113. In this instance, the PIC has a high level of skill, 

has a more than basic knowledge of the NAS and as a current member of the AMA abides by their safety

and technical requirements. He has vested both money and time in training and educating himself for this 

particular type of flight and commercial use.

The FAA has concluded in the NPRM that such UA-specific is more than sufficient to provide an 

equivalent level of safety for UA operations. Sometime in the next 18 to 24 months, that position will be 

enshrined in a valid regulation. However in the meantime, the FAA claims it lacks the authority to relax 

the requirement to possess a pilot certificate. As described infra, that position is both incorrect and 

contradicted by the FAA’s recent decisions.

3. THE FAA HAS ALREADY EXERCISED THE AUTHORITY TO EXEMPT 

APPLICANTS FROM THE AIRMAN CERTIFICATE REQUIREMENT

5 Civil Aviation Authority, Safety Regulation Group, Unmanned Aircraft Systems Operations in UK 

Airspace – Guidance, Section 2, Chapter 5, Page 2 (Aug. 10, 2012), available at

https://www.caa.co.uk/docs/33/CAP722.pdf. 

6 Civil Aviation Authority, Unmanned Aircraft and Aircraft Systems, available at

http://www.caa.co.uk/default.aspx?catid=1995&pagetype=90

7 Australian Government Civil Aviation Safety Authority, available at

http://www.casa.gov.au/scripts/nc.dll/WCMS:STANDARD::pc=PC_100374. 
TOBIN R. COOLEY Petition for Exemption pg. 9

7

See Euro USC International, Pilot Qualifications,” available at

http://eurousc.com/services/pilot-qualifications/. 

The FAA claims that it lacks authority to exempt UA operators from the requirement of 49 

U.S.C. §44711 to hold an airman certificate authorizing the airman “to serve in the capacity for which the 

certificate was issued.” See e.g., Exemption No. 11110 at 14. This claim is inconsistent with both (i) the 

statutory language of that section and Section 333, and (ii) numerous recent FAA decisions.

The operative of 49 U.S.C. §44711 provides that a “person may not...serve in any capacity as an 

airman with respect to a civil aircraft,...used, or intended for use, in air commerce – (A) without an 

airman certificate authorizing the airman to serve in the capacity for which the certificate was issued...” If 

the FAA’s interpretation were correct, this language would require that any person wishing to operate a 

UA for commercial operations have an airman certificate authoring the person to serve as an airman in 

commercial operations.

However, in all of its recent grants of Section 333 petitions, the FAA has – without explicitly 

acknowledging the fact – exempted commercial UA operators from the §47111(A) requirement that they 

hold an airman certificate authorizing them “to serve in the capacity for which the certificate was issued.” 

T has done so by allowing them to operate a UA so long as they hold a private pilot’s or sport pilot’s 

authorization, even though such a certificate does not permit commercial operations. Exemption No. 

11062 at 15-18; Exemption No. 11110 at 14-16; Exemption No. 11191 at 3-5; Exemption No. 11229 at 3 

and 8.

The FAA argues that it cannot exempt applicants from the requirements of §44711 because, while 

the specific language of Section 333 grants it limited statutory flexibility relative to 49 U.S.C. §44704 for 

the purposes of airworthiness certification, Section 333 does not provide flexibility relative to §44711 and 

other sections of Title 49. Exemption No. 11110 at 14. This argument ignores the plain language of the 

statute. The relevant language of Section 333 is:

(a) IN GENERAL.-Notwithstanding any other requirement of this subtitle, and not later than 

180 days after the date of enactment of the Act, the Secretary of Transportation shall determine if 

certain unmanned aircraft systems may operate safely in the national airspace system before 

completion of the plan and rulemaking required by section 332 of this Act or the guidance 

required by section 334 of this Act.

(b) ASSESSMENT OF UNMANNED AIRCRAFT SYSTEMS.-In making the determination 

under subsection (a), the Secretary Shall determine, at a minimum-

(1) which types of unmanned aircraft systems, if an, as a result of their size, weight, speed, 

operational capability, proximity to airports and populated areas, and operation within visual line 

of sight do not create a hazard to users of the national airspace system or the public or pose a 

threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification 

under section 444704 of title 49, United States Code, is required for the operation of unmanned 

aircraft systems identified under paragraph (1).
TOBIN R. COOLEY Petition for Exemption pg. 10

(c) REQUIREMENTS FOR SAGE OPERATION.-If the Secretary determines under this 

section that certain unmanned aircraft systems may operate safely in the national airspace system, 

the Secretary shall establish requirements for the safe operation of such aircraft systems in the 

national airspace system.

The language of Section 333(b) is permissive: it requires that the Secretary “determine, at a 

minimum...whether a certificate of waiver, certificate of authorization, or airworthiness certification 

under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft 

systems identified under paragraph (1).” Nothing in (b) precludes the Secretary from determining whether 

or not a pilot’s license is required for operation of a UA identified under paragraph (b)(1).

Indeed, the FAA has implicitly conceded the point by granting exemptions from the requirement 

that commercial UA operators hold a commercial pilot certificate. From an analytical standpoint, there is 

no difference between granting an exemption from the commercial pilot’s license requirement and 

granting an exemption from the private or sport pilot’s license requirement. Both are clearly exemptions 

from a specific statutory requirement in 49 U.S.C. §44711. If the FAA has the statutory authority under 

Section 333(b) to do the former, it has the same authority to do the latter.8

For the reasons set forth above, the FAA should reconsider its position and exercise its full 

authority to grant an exemption from all the requirements of 49 U.S.C. §44711, so that SSP serving as a 

commercial mUAS operator need not have a pilot’s license.

Alternatively:

1. TOBIN R. COOLEY SEEKS EXEMPTION FROM THE REQUIREMENTS OF 

SECTION 61.113(a) and (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) 

and (b) prescribe the following, in relevant part:

8 The FAA has not specifically identified the statutory provision that underpins its authority to grant the 

exemptions from the commercial pilot’s license requirement. Whether the statutory basis is Section 333 

or some other provision makes no difference. If there is a basis for a partial exemption from in 49 U.S.C. 

§44711, that basis also justifies an exemption from the entire provision.

(a) No person who holds a private pilot certificate may act as a PIC (pilot in command) of an 

aircraft that is carrying passengers or property for compensation or hire; nor may that person, for 

compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any

business or employment if-

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

2. TOBIN R. COOLEY SEEKS EXEMPTION FROM THE REQUIREMENT OF 

SECTION 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following:
TOBIN R. COOLEY Petition for Exemption pg. 11

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. TOBIN R. COOLEY SEEKS EXEMPTION FROM THE REQUIREMENTS OF 

SECTION 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that 

aircraft, as the case may be, by reference to an altimeter that is set, when operating—

(1) Below 18,000 feet MSL, to—

(i) The current reported altimeter setting of a station along the route and within 100 

nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, 

the current reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure 

airport or an appropriate altimeter setting available before departure.

4. TOBIN R. COOLEY SEEKS EXEMPTION FROM THE REQUIREMENTS OF 

SECTION 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the 

following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind 

and forecast weather conditions) there is enough fuel to fly to the first point of intended landing 

and, assuming normal cruising speed, to fly after that for at least 20 minutes.

5. TOBIN R. COOLEY SEEKS EXEMPTION FROM THE REQUIREMENT OF 

SECTION 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following:

Each owner or operator of an aircraft—

(a) 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[.]

6. TOBIN R. COOLEY SEEKS EXEMPTION FROM THE REQUIREMENTS OF 

SECTION 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or 

alteration, subsection (a)(1), states the following:

(a) No person may operate ay aircraft that has undergone maintenance, preventive maintenance, 

rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under § 43.7 of this 

chapter.
TOBIN R. COOLEY Petition for Exemption pg. 12

7. TOBIN R. COOLEY SEEKS EXEMPTION FROM THE REQUIREMENTS OF 

SECTIONS 91.409(a)(1) and 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, 

within the preceding 12 calendar months, it has had—

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by § 43.7 of this chapter: or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 

21 of this chapter.

8. TOBIN R. COOLEY SEEKS EXEMPTION FROM THE REQUIREMENTS OF 

SECTIONS 91.417(a) and 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner 

or operator shall keep the following records for the periods specified in paragraph (b) of this 

section:

1) Records of the maintenance, preventive maintenance, and alteration and records of the 

100-hour, annual, progressive and other required or approved inspections, as appropriate, 

for each aircraft (including the airframe) and each engine, propeller, rotor and appliance 

of an aircraft. The records must include—

i) A description (or reference to data acceptable to the Administrator) of the work 

performed; and

ii) The date of completion of the work performed; and

iii) The signature, ad certificate number of the person approving the aircraft for return to 

service.

2) Records containing the following information:

i) The total time in service of the airframe, each engine, each propeller, and each rotor.

ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and 

appliance.

iii) The time since last overhaul of all items installed on the aircraft which are required to 

be overhauled on a specified time basis.

iv) The current inspection status of the aircraft, including the time since the last 

inspection required by the inspection program under which the aircraft and its 

appliances are maintained.
TOBIN R. COOLEY Petition for Exemption pg. 13

v) The current status of applicable airworthiness directives (AD) and safety directives 

including, for each, the method of compliance, the AD or safety directive number and 

revision date, if the AD or safety directive involves recurring action, the time and 

date when the next action is required.

vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration 

to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

1) The records specified in paragraph (a)(1) of this section shall be retained until te work is 

repeated or superseded by other work or for 1 year after the work is performed.

2) The records specified in paragraph (a)(2) of this section shall be retained and transferred 

with the aircraft at the time the aircraft is sold.

3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter 

shall be retained until the defects are repaired and the aircraft is approved for return to 

service.

C. THE EXTENT OF RELIEF TOBIN R. COOLEY SEEKS AND THE REASON TOIBN R. 

COOLEY SEEKS THE RELIEF

1. EXTENT OF RELIEF TOBIN R. COOLEY SEEKS AND THE REASON TOBIN R. 

COOLEY SEEKS RELIEF FROM SECTION 61.113(a) and (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in 

command, is requested to the extent necessary to allow a PIC holding a FAA airman certificate or in the 

alternative an unmanned aircraft operator certificate with a micro UAS rating (like existing pilot airman 

certificates) as well as a current and valid airman medical certificate, and who has met certain flight-hour 

and currency requirements, to conduct the proposed mUAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private 

pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or 

employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does 

not carry passengers or property for compensation or hire.

As set forth more fully below, Tobin R. Cooley submits that an equivalent level of safety will be 

maintained because no PIC will be allowed to operate the Cheerson CX-20 mUAS unless that PIC has 

met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely operate the 

Cheerson CX-20 mUAS in a manner consistent with the operations specifications as described in this 

exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances 

from people, vessels, vehicles and structures.

Further, Tobin Cooley submits that all flights of the Cheerson CX-20, conducted by the PIC pursuant 

to the grant of this petition: (1) will be incidental to Tobin Cooley’s assumed business; and (2) will not 

carry passengers or property for compensation or hire.

2. EXTENT OF RELIEF TOBIN R. COOLEY SEEKS AND THE REASON TOBIN 

COOLEY SEEKS RELIEF FROM SECTION 91.7(a).
TOBIN R. COOLEY Petition for Exemption pg. 14

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to 

allow Tobin R. Cooley to determine that the Cheerson CX-20 is in airworthy condition prior to every 

flight by ensuring that the mUAS is in compliance with the operating documents (i.e., assumed business 

flight operations manual, maintenance log, and Cheerson CX-20 instruction manual).

Tobin R. Cooley seeks the requested relief because the Cheerson CX-20 mUAS does not require an 

airworthiness certificate in accordance with 14 C.F.R Part 21, Subpart H. Therefore, Tobin R. Cooley will 

ensure that the Cheerson CX-20 mUAS is in airworthy condition based upon its compliance with the 

operating documents (i.e., Monthly Maintenance Log and the Cheerson CX-20 instruction manual) prior 

to every flight, and further determine that the aircraft is in condition for safe flight, as stated in the 

conditions and limitations below.

3. EXTENT OF RELIEF TOBIN R. COOLEY SEEKS AND THE REASON TOBIN R. 

COOLEY SEEKS RELIEF FROM SECTION 91.121.

Relief from section 91.121, entitled Altimeter settings, may be required to allow flight operations of 

the Cheerson CX-20 mUAS, which utilize a barometric pressure senor, GPS equipment, and a radio 

communications telemetry data link to downlink attitude information from the mUAS to the PIC at the 

ground control station (GCS). Since the FAA requires that any altitude information concerning mUAS 

operations be reported to air traffic control (ATC) in feet above ground level (AGL), Tobin R. Cooley 

seeks the requested relief because the Cheerson CX-20 mUAS altimeter may be set on the ground to zero 

feet AGL, rather than the local barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to 

the extent necessary to comply with the applicable conditions and limitations stated below. As more fully

set forth herein, an equivalent level of safety will be maintained since the Cheerson CX-20 mUAS are 

equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a 

ground level pressure setting will be established prior to each flight, and provides the PIC with altitude 

information of the mUAS on the heads-up display of the CGS.

4. EXTENT OF RELIEF TOBIN R. COOLEY SEEKS AND THE REASON TOBIN R. 

COOLEY SEEKS RELIEF FROM SECTION 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to 

the extent required to allow flights of the battery powered Cheerson CX-20 mUAS during daylight hours 

in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 10 

minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at 

least 2 minutes. Tobin R. Cooley seeks the requested relief because without an exemption from Section 

91.151(b), the flight time duration of the battery powered Cheerson CX-20 mUAS will severely constrain 

the practicality of any aerial video or still photo flight operations that Tobin R. Cooley proposes to 

conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the Cheerson CX-20 mUAS, the 

Cheerson CX-20 mUAS operating documents, and Tobin R. Cooley’s proposed operating limitations, 

ensure that Tobin R Cooley will safely operate the battery powered Cheerson CX-20 mUAS during 

daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough 

battery power to fly for a total duration of 10 minutes to the first point of intended landing and, assuming

normal cruising speed, to fly after that for at least 2 minutes.
TOBIN R. COOLEY Petition for Exemption pg. 15

5. EXENT OF RELIEF TOBIN R. COOLEY SEEKS AND THE REASON TOBIN R. 

COOLEY SEEKS RELIEF FROM SECTIONS 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), AND 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to 

aircraft with an airworthiness certificate, Tobin R. Cooley requests relief from these Sections because the 

Cheerson CX-20 mUAS does not require airworthiness certificate. As set forth more fully below, the 

Cheerson CX-20 mUAS meets the conditions of FMRA Section 333 for operation without an 

airworthiness certificate. Accordingly, Tobin R. Cooley will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the Cheerson CX-20 mUAS using the methods, 

techniques, and practices prescribed in the mUAS operating documents (i.e., the assumed business flight 

operations manual, Monthly Maintenance Log, and the Cheerson CX-20 mUAS instruction manual). 

Furthermore, Tobin R. Cooley will document and maintain all maintenance records for the Cheerson CX20 mUAS.

D. REASONS WHY GRANTING TOBIN R. COOLEY’S REQUEST WOULD BE IN THE PULIC 

INTEREST.

Granting this Petition will further the public interest by allowing Tobin R. Cooley too safely, 

efficiently, and economically perform aerial video and photography of construction sites, real estate, and 

landscape over certain areas of the United States.

Additionally, use of the Cheerson CX-20 mUAS will decrease congestion of the NAS, reduce 

pollution, and provide significant benefits to the economy. Notably, the benefits of Tobin R. Cooley’s 

proposed operation of the Cheerson CX-20 mUAS will be realized without implicating any privacy

issues.

1. THE PUBLIC WILL BEBEFIT FROM DECREASED CONSGESTOION OF THE 

NAS.

The Cheerson CX-20 mUAS is battery powered and serve as a safe, efficient, and economical 

alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amont o 

manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of the Cheerson 

CX-20 mUAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as 

well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion 

around airports caused by arriving and departing aircraft will be reduced. The Cheerson CX-20 mUAS 

does not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial 

video and photography missions would result in fewer aircraft that must be handled by air traffic control 

during the ground takeoff, departure, arrival, and landing phases of flight operations.

2. THE PUBLIC WILL BENEFIT FROM THE SAFETY AND EFFICIENCY OF THE 

CHEERSON CX-20 mUAS.

Conducting aerial acquisitions with the Cheerson CX-20 mUAS, instead of manned aircraft, will 

greatly benefit the public by drastically reducing the levels of air and noise pollution generated during 

traditional aerial video and still photography flight operations. By using the battery power and electric 

motors, the Cheerson CX-20 mUAS produce no air pollution, and is the most viable environmentally 

conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically

utilized for aerial video ad photography, while burning approximately 20-30 gallons per hour of leaded 
TOBIN R. COOLEY Petition for Exemption pg. 16

aviation fuel. The Cheerson CX-20 mUAS, while reducing the carbon footprint of aerial acquisitions, also 

eliminates noise pollution, as the Cheerson CX-20 mUAS is propelled by battery powered electric 

motors, rather than an internal combustion engine.

By using the Cheerson CX-20 mUAS to perform aerial acquisitions, the substantial risk to life 

and property in the air and on the ground, which is usually associated with traditional manned aircraft 

flight operations, will be substantially reduced or completely eliminate. Aside from the lack of flight crew 

members located onboard the aircraft, the Cheerson CX-20 mUAS (weighing approximately 2 pounds 

respectively, with a width of 20 3⁄4” X 20 3⁄4” respectively, and with no fuel on board), has less physical 

potential for collateral damage to life and property on the ground, and in the air, compared to the manned 

aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan 

of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. PERFORMING AERIAL VIDEO AND PHOTOGRAPHY OPERATIONS WITH THE 

CHEERSON CX-20 mUAS WILL BENEFIT THE ECONOMY.

In addition to being safe and efficient, the Cheerson CX-20 mUAS is also an economical 

alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the 

Cheerson CX-20 mUAS will allow United States based companies, like the business of Tobin R. Cooley, 

to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of 

aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded 

aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to 

remain competitive. Operating the battery powered Cheerson CX-20 mUAS is one such technology that 

not only allows companies greater operational flexibility compared to manned aircraft, but provides such 

flexibility without the high operational cost of a traditional manned aircraft.

By operating the Cheerson CX-20 mUAS, companies such as that of Tobin R. Cooley, can 

remain competitive and profitable, and therefore, provide greater job stability to employees and 

contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial 

performance of U.S. companies, through commercial use of the Cheerson CX-20 mUAS, provides a 

stable workforce that increases consumer spending, improves local, State, and Federal tax revenues, and 

allows companies to invest in research and development in order to remain competitive both in the United 

States and abroad.

4. THERE ARE NO PRIVACY ISSUES.

Similar to the manned aerial acquisition flight operations that have been conducted for decades, 

Tobin R. Cooley’s proposed operation of the Cheerson CX-20 mUAS will not implicate any privacy 

issues. Specifically, the Cheerson CX-20 mUAS will be operated only in compliance with operating 

documents (i.e., the assumed business Flight Operations Manual, Monthly Maintenance Log, and the 

Cheerson CX-20 mUAS Instruction Manual) which requires property owner/representative involvement 

as well as signage (aerial photography in progress) placed in a conspicuous manner, and in accordance 

with the Federal Aviation Regulations, including altitude requirements of 14 C.F.R. § 91.119.

E. REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT 

SAFETY, OR HOW THE EXEMPTION WOULD PROVEDE A LEVEL OF SAFETY AT LEAST 

EQUAL TO THAT PROVIDED BY THE RULE FROM WHICH TOBIN R. COOLEY SEEKS 

EXEMTION.

1. REASONS WHY THE CHEERSON CX-20 mUAS MEET THE CONDITIONS OF THE 

FAA MODERNIZATION ANDREFOM ACT OF 2012 (FMRA) SECTION 333.
TOBIN R. COOLEY Petition for Exemption pg. 17

In consideration of the size, weight, speed and limited operating area associated with the 

unmanned aircraft and its operation, Tobin R. Cooley’s operation of the Cheerson CX-20 mUAS meet the 

conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H.

Section 333 provides authority for a mUAS to operate without airworthiness certification and sets 

forth requirements for considering whether a mUAS will create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the 

following, in part:

a) In General.-Notwithstanding any other requirement of this subtitle, and not later than 

180 days after the date of enactment of this Act, the Secretary of Transportation shall 

determine if certain unmanned aircraft systems may operate safely in the national 

airspace system before completion of the plan and rulemaking required by section 332 of 

this Act of the guidance required by section 334 of this Act.

b) Assessment of Unmanned Aircraft Systems.—In making the determination under 

subsection (a), the Secretary shall determine, at a minimum—

1) which types of unmanned aircraft systems, if any, as a result of their size, weight, 

speed, operational capability, proximity to airports and populated areas, and operation 

within visual line of sight do not create a hazard to users of the national airspace system 

of the public or pose a threat to national security; and

2) whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required for the 

operation of unmanned aircraft systems identified under paragraph (I).

(c) Requirements for Safe Operation.—If the Secretary determines under this section that certain 

unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall 

establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, Tobin R. Cooley submits that the Cheerson CX-20 mUAS can operate 

safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the

Cheerson CX-20 mUAS, (b) the pilot certification requirement, and (c) the specific operating limitations.

a. THE OPERATION SPECIFICATIONS OF THE CHEERSON CX-20 mUAS 

DEMONSTRATE ITS SAFE CHARACTERISTICS.

The Cheerson CX-20 mUAS does not create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security considering its size, weigh, speed, frangible materials, and 

operational capability.

i. OPERATION SPECIFICATIONS OF THE CHEERSON CX-20

The oeration specifications of the Cheerson CX-20 mUAS are set forth by the Cheerson CX-20 

operation manual, attached hereto as exhibit A.

ii. THE CHEERSON CX-20 mUAS AUTONOMOUS FLIGHT CAPABILITY 

ENABLES THE mUAS TO REMAIN WITHIN A DEFINED OPERATIONAL AREA.
TOBIN R. COOLEY Petition for Exemption pg. 18

The Cheerson CX-20 mUAS has the capability of full autonomous flight with programmable 

destinations and altitudes, keeping the mUAS within a defined operational area. A description of 

navigational options is included in exhibit A.

iii. THE CHEERSON CX-20 mUAS IS EQUIPPED WITH AUTONOMOUS 

FAILSAFES IN THE CASE OF (a) LOSS OF LINK (LOL) WITH THE GROUND CONTROL 

STATION (GCS), OR (b) WHEN VOLTAGE OF BATTERY IS TOO LOW.

(a) In the event of a loss of link (LOL) with the ground control station (GCS) the Cheerson CX20 mUAS is equipped with autonomous return to home mode, where the Cheerson CX-20 mUAS 

automatically climbs to or drops to an altitude of approximately 40 feet above ground level (AGL), and 

then returns to the ground control station (GCS) where it safely lands its self. 

(b) When the voltage of the battery becomes too low, the Cheerson CX-20 mUAS will 

automatically safely land its self.

b. FLIGHT OPERATONS OF THE CHEERSON CX-20 mUAS ARE LIMITED TO THE 

LINE OF SIGHT OF A CERTIFICATED PILOT IN COMMAND WITH A SAFETY 

OBSERVER.

Tobin R. Cooley will only utilize certificated pilots to act as a pilot in command (PIC) of the 

Cheerson CX-20 mUAS. Additionally, a safety observer will assist all pilots during flight time.

c. FLIGHTS OF CHEERSON CX-20 mUAS WILL BE CONDUCTED PURSUANT TO 

SPECIFIC OPERATING LIMITATIONS.

In seeking this exemption, Tobin R. Cooley proposes to commercially operate the Cheerson CX20 mUAS for the special purpose of conducting aerial video and photography over certain areas of the 

United States, pursuant to the following specific operating limitations:

1) Operations authorized by this grant of exemption will be limited to the following aircraft described in 

the operating documents, rotorcraft mUAS weighing less than 55 pounds maximum gross weight: 

Cheerson CX-20 micro-Unmanned Aircraft System. Proposed operations of any other aircraft will 

require a new petition or a petition to amend this grant.

2) mUAS operations under this exemption will be limited to conducting operations for the purpose of 

aerial video and photography.

3) The mUAS may not be flown at an indicated airspeed exceeding 20 knots.

4) The mUAS must be operated at an altitude of no more than 500 feet above ground level (AGL), as 

indicated by the procedures specified in the operating documents unless a special request is made and 

approved by ATC. All altitudes reported to ATC must be in feet AGL.

5) The mUAS must be operated within visual line of sight (VLOS) of the PIC at all times. This requires 

the PIC to be able to use human vision unaided by any device other than corrective lenses, as 

specified on the PIC’s FAA-issued airman medical certificate.

6) The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.
TOBIN R. COOLEY Petition for Exemption pg. 19

7) All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to 

communicate verbally at all times. Electronic messaging or texting is not permitted during flight 

operations. The PIC must be designated before the flight and cannot transfer his or her designation for 

the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the 

operating documents.

8) The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other 

air traffic and other ground based obstacle/obstructions and is not permitted to operate the camera or 

other instruments.

9) The operating documents and the grant of exemption must be accessible during mUAS operations and 

made available to the Administrator upon request. If a discrepancy exists between the conditions and 

limitations contained in the grant of exemption and the procedures outlined in the operating 

documents, the conditions and limitations contained in the grant of exemption take precedence and 

must be followed. Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the operator’s 

responsibility to track such revisions and present updated and revised documents upon request. The 

operator must also present updated and revised documents if it petitions for extension or amendment 

to the grant of exemption. If the operator determine that any update or revision would affect the basis 

upon which the FAA granted the exemption, then the operator must petition for amendment to its 

grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise 

regarding updates or revisions to the operating documents.

10) Prior to each flight the PIC must inspect the mUAS to ensure that it is in a condition for safe flight. If 

the inspection reveals a condition that affects the safe operation of the mUAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the mUAS is 

found to be in a condition for safe flight. The Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be properly documented in the aircraft 

records.

11) Any mUAS that has undergone maintenance or alterations that affect the mUAS operation of flight 

characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. 

The PIC who conducts the functional test flight must make an entry in the aircraft records.

12) The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, 

items, or equipment, not already covered in the relevant sections of the operating documents.

13) The operator must follow the mUAS manufacturer’s aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements.

14) The operator must carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance, inspection, alterations, and status of 

replacement/overhaul component parts must be noted in the aircraft records, including total time in 

service, description of work accomplished, and the signature of the authorized person returning the 

mUAS to service.

15) Each mUAS operated under this exemption must comply with all manufacturer Safety Bulletins.

16) The authorized person must make an entry in the aircraft record of the corrective action taken against 

discrepancies discovered between inspections.
TOBIN R. COOLEY Petition for Exemption pg. 20

17) The PIC must possess at least a private pilot certificate and at least a current third-class medical 

certificate.

18) The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification 

criteria and demonstrates the ability to safely operate the mUAS in a manner consistent with how the 

mUAS will be operated under the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification 

flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes 

of training the operator’s PICs are permitted under the terms of the exemption. However, training

operations may only be conducted during dedicated training sessions. During training, proficiency, 

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

nonparticipants, and the PIC must operate the mUAS with appropriate distance form nonparticipants 

in accordance with 14 C.F.R § 91.119.

19) mUAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations 

must be conducted under visual meteorological conditions (VMC). If flight at night is required, a 

special request will be made at the FAA office closest to proposed area of operations. Flights under 

special visual flight rules (SVFR) are not authorized.

20) The mUAS may not operate 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 

is obtained, and the operation is conducted in accordance with a NOTAM as required by the 

operator’s COA. The letter of agreement with the airport management must be made available to the 

Administrator upon request.

21) The mUAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a 

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

22) If the mUAS loses communications or loses its GPS signal, it must return to a pre-determined 

location within the planned operating area ad land or be recovered in accordance with the operating 

documents.

23) The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with 

the operating documents.

24) The PIC is prohibited from beginning 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 mUAS with 25% battery power remaining.

25) The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

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

also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, 

but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with 

airspace requirements in the ATO issued COA including class of airspace, altitude level and potential 

transponder requirements.

26) All aircraft operated in accordance with the exemption must be identified by serial number, registered 

in accordance with 14 C.F.R part 47, and have identification (N- Number) markings in accordance 

with 14 C.F.R part 45, Subpart C. Markings must be as large as practicable.
TOBIN R. COOLEY Petition for Exemption pg. 21

27) Before conducting operations, the radio frequency spectrum used for operation and control of the 

mUAS must comply with Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements.

28) The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the mUAS any time the mUAS is operating. These documents must be 

made available to the Administrator or any law enforcement official upon request.

29) The mUAS must remain clear and yield the right of way to all manned aviation operations and 

activities at all times.

30) The mUAS may not be operated by the PIC from any moving device or vehicle.

31) Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other 

than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a) Barriers or structures are present that sufficiently protect nonparticipating persons from the 

mUAS and/or debris in the event of an accident. The operator must ensure that nonparticipating 

persons remain under such protection. If a situation arises where nonparticipating persons leave 

such protection and are with 500 feet of the mUAS, flight operations must cease immediately 

and/or;

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, and;

c) Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue 

hazard to those persons per § 91.119(a).

32) All operations shall be conducted over private or controlled-access property with permission from the 

land owner/controller or authorized representative. Permission from land owner/controller or 

authorized representative will be obtained for each flight to be conducted.

33) Any incident, accident, or fight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA must be reported to the FAA’s UAS Integration 

Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety 

Board (NTSB) per instructions contained on the NTSB Web site:www.ntsb.gov.

2. REASONS WHY AN EXEMPTION FROM TH REQUIREMENTS OF SECTION 61.113(a) 

AND (b) WOULD NOT ADVERSELY AFFECT SAFETY.

Tobin R. Cooley submits that the equivalent level of safety established by Section 61.113(a) and 

(b) will be maintained because no PIC will be allowed to operate the Cheerson CX-20 mUAS unless that 

PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to 

safely operate the Cheerson CX-20 in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures.

Considering Tobin R. Cooley’s proposed area of operations, and the airmanship skills necessary 

to safely operate the Cheerson CX-20 mUAS, Tobin R. Cooley submits that the additional manned 
TOBIN R. COOLEY Petition for Exemption pg. 22

airmanship experience of a certificated pilot would not correlate to the airmanship skills necessary for 

Tobin R. Cooley’s specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11159, 11160, 

11161).

Tobin R. Cooley will not allow any PIC to operate the Cheerson CX-20 mUAS unless that PIC 

has demonstrated, by meeting minimum flight-hour requirements or the Cheerson CX-20 mUAS training 

and currency requirements, that the PIC is able to safely operate the Cheerson CX-20 mUAS in a manner 

consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 

61.51(b), 25 hours of total time as a mUAS rotorcraft pilot (with a minimum of 5 hours of those hours as 

a mUAS pilot operating the same make and model of mUAS to be used for operations under the 

exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the 

preceding 90 days (for currency purposes).

As in exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was 

obtained in compliance with applicable regulations will ensure an equivalent level of safety during Tobin 

R. Cooley’s proposed operations. The Administrator has held that prior documented flight experience that 

was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of 

motion picture filming (or similar operations), the PIC must have accumulated and logged, in a 

manner consistent with 14 C.F.R 61.51(b), 25 hours of total time as a UAS rotorcraft pilot 

including at least 10 hours logged as UAS pilot with a multi-rotor UAS. Prior to operations under 

Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as 

a UAS pilot operating the same make and model of UAS to be used for operations under the 

exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive 

rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multirotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In

addition to the hour requirements, the PIC must accomplish 3 take offs and landings in the 

preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight-hour 

requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the 

skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that 

prior documented flight experience that was obtained in compliance with applicable regulations 

would satisfy this requirement. Training, proficiency, and experience-building flights can also be 

conducted under the grant of exemption to accomplish the required flight time. During training, 

proficiency, and experience-building flights the PIC is required to operate the UA with 

appropriate distances in accordance with 14 F.C.R 91.119.

Accordingly, Tobin R. Cooley will ensure safe operations by not allowing any PIC to operate the 

Cheerson CX-20 mUAS unless that PIC has demonstrated, by meting minimum flight-hour and currency 

requirements, that the PIC is able to safely operate the Cheerson CX-20 mUAS in a manner consistent 

with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures.
TOBIN R. COOLEY Petition for Exemption pg. 23

3. REASONS WHY AN EXEMPTION FROM THE REQUIREMENTS OF SECTION 

91.7(a) WOULD NOT ADVERSELY AFFECT SAFETY.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to 

every flight, Tobin R. Cooley will ensure that the Cheerson CX-20 is in an airworthy condition based 

upon the mUAS’s compliance with its operating documents and as stated in the conditions and limitations 

herein.

Additionally, The FAA has previously granted relief from Section 91.7(a) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161).

4. REASONS WHY AN EXEMPTION FROM THE REQUIREMENTS OF SECTION 

91.121 WOULD NOT ADVERSELY AFFECT SAFETY.

The equivalent level of safety established by Section 91.121 will be maintained because the 

altitude information of the Cheerson CX-20 mUAS will be provided to the PIC via GPS equipment and a 

radio communications telemetry data link, which downlinks from the mUAS to the GCS for active 

monitoring ot the flight path and altitude. This altitude information, combined with Tobin R. Cooley’s 

operation of the Cheerson CX-20 mUAS within visual line of sight, at or below 400 feet AGL, will 

ensure a level of safety equivalent to Section 91.121. The latitude information will be generated by GPS 

equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is 

automatically established by the mUAS at ground level.

The FAA has previously granted relief from Section 91.121 to UAS, in circumstances similar, in 

all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 159, 1160, 

11161).

5. REASONS WHY AN EXEMPTION FORM THE REQUIREMENTS OF SECTION 

91.151(b) WOULD NOT ADVERSELY AFFECT SAFETY.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. 

Section 91.151(b) as a result of (1) the operation specifications of the Cheerson CX-20 mUAS; (2) the 

limitations on the proposed flight operations; and (3) the location of the proposed flight operations. 

Accordingly, Tobin R. Cooley will ensure that is will safely operate the battery powered Cheerson CX-20 

mUAS during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 

10 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for 

at least 2 minutes.

Here, as in Exemption No. 11109, the operation specifications of the Cheerson CX-20 mUAS; the 

limitations on the proposed flight operations; and the location of the proposed operations, will ensure an 

equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured 

as the Cheerson CX-20 mUAS provide audible and visual warnings to the PIC at the GCS when the 

mUAS experiences low battery voltage, the first warning occurring at approximately 33% remaining

battery power, and again at approximately 10% remaining battery power. At the critically low battery 

level, the Cheerson CX-20 mUAS will descend and land automatically.
TOBIN R. COOLEY Petition for Exemption pg. 24

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that 

safety is no adversely affected when the operational characteristics and operating limitations of the mUAS 

are considered. Relief as been granted for manned aircraft to operate at less than the minimum prescribed 

in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously 

granted relief from Section 91.151 specific to UAS, in circumstances similar, in all bacterial respects, to 

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 

11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157,11158, 11159, 11160, 

11161).

6. REASON WHY AN EXEMPTON FROM THE REQUIREMENTS OF SECTIONS 

91.405(a), 91.407(a)(1), 91.409(a)(1), & (a)(2), and 91.417(a) and (b) WOULD NOT 

ADVERSELY AFFECT SAFETY.

In seeking this exemption, Tobin R. Cooley submits that the equivalent level of safety with regard 

to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1) 

& (a)(2), and 91.417(a) & (b) will be met because Tobin R. Cooley will use trained technicians to 

perform maintenance, alterations, or preventive maintenance on the mUAS using the methods, 

techniques, and practices prescribed in the operating documents (i.e. the assumed business Flight 

Operations Manual, Monthly Maintenance Log, and the Cheerson CX-20 mUAS operation manual). 

Furthermore, Tobin R. Cooley will document and maintain all maintenance records for the Cheerson CX20 mUAS.

Since the Cheerson CX-20 mUAS will be inspected as prescribed by the operating documents, 

Tobin R. Cooley will maintain the equivalent level of safety established by Sections 91.405(a), 

91.409(a)(1), and 91.409(a)(2). A copy of the Cheerson CX-20 mUAS operation manual is attached

hereto as Exhibit A.

Likewise, the exemption sought will not adversely affect safety because Tobin R. Cooley will use 

trained technicians to perform maintenance, alterations or preventive maintenance on the mUAS using the 

methods, techniques, and practices prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety established by 

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the Cheerson CX-20 mUAS will be 

performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly 

maintenance log.

Significantly, previous exemptions grated by the FAA concerning Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected 

when the technical characteristics and operating limitations of the mUAS are considered.

In consideration of Tobin R. Cooley’s proposed operating limitations, the operating documents, 

and the technical aspects of the Cheerson CX-20 mUAS, Tobin R. Cooley submits that safety will not be 

adversely affected by granting exemption from 14 C.F.R Sections 91.405(a), 91.407(a)(1) and (a)(2), 

91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161).

7. THE FAA MAY PRESCRIBE ANY OTHER CONDITIONS FOR SAFE OPERATION.
TOBIN R. COOLEY Petition for Exemption pg. 25

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 

14 C.F.R. § 21.16 entitled Special Conditions, Tobin R. Cooley requests that the FAA prescribe special 

conditions for the intended operation of the Cheerson CX-20 mUAS, which contain such safety standards 

that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 

C.F.R. Part 21, Subpart H, and 14 C.F.R. §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe 

operation of the mUAS for the limited purpose of conducting aerial video and photography over certain 

areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for 

considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a 

threat to national security, and further, provides the authority for such UAS to operate without 

airworthiness certification in accordance with any requirements that must be established for the safe 

operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for 

operation of the Cheerson CX-20 mUAS, since the airworthiness regulations of 14 C.F.R. part 21 do not 

contain adequate or appropriate safety standards, due to the novel or unusual design features of the 

aircraft. Section 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or 

appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or 

unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions 

and amendments thereto for the product. The special conditions are issued in accordance with 

Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or 

propeller as the FAA finds necessary to establish a level of safety equivalent to that established in 

the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe 

special conditions for Tobin R. Cooley’s intended operation of the Cheerson CX-20 mUAS, which 

contain such safety standards that the Administrator finds necessary to establish a level of safety 

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R. Sections 61.113(a) & (b), 

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

F. A SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER, STATING: THE 

RULES FROM WHICH TOBIN R. COOEY SEEKS EXEMPTION:

Tobin R. Cooley seeks exemption from the requirements of 14 C.F.R. Sections 61.113(a) & (b), 

alternatively 14 C.F.R. section 61.113, and 91.7(a), 91.121, 91.151(b) 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A BRIEF DESCRIPTION OF THE NATURE OF THE EXEMPTION TOBIN R. 

COOLEY SEEKS:

This exemption will permit Tobin R. Cooley to commercially operate an Micro Unmanned 

Aircraft System (mUAS) for the purpose of conducting aerial video and photography over 

allowed areas of the United States.

G. ANY ADDITONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT TOBIN R. COOLEY’S REQUEST.
TOBIN R. COOLEY Petition for Exemption pg. 26

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) 

Section 333, which directs the Secretary of Transportation to determine if certain UAS (mUAS) may 

operate safely in the NAS. As such, Tobin R. Cooley’s request for exemption may be granted pursuant to 

the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, 

provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, Tobin R. Cooley will operate the Cheerson CX-20 mUAS safely in 

the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to 

national security.

CONCLUSION

As set forth herein, Tobin R. Cooley seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe 

operation of the Cheerson CX-20 mUAS commercially, without an airworthiness certificate, for the 

limited purpose of conducting aerial video and photography over certain areas of the United States. By 

granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA 

Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing 

Tobin R. Cooley to safely, efficiently, and economically operate the Cheerson CX-20 mUAS 

commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, Tobin R. Cooley respectfully requests that the 

Administrator grant this Petition for an exemption from the requirements of 14 C.F.R. Sections 61.113(a) 

& (b) or alternatively 14 C.F.R. Sections 61.113, 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Tobin R. Cooley to operate the Cheerson CX-20 

mUAS commercially for the purpose of conducting aerial video and photography over certain areas of the 

United States.

Dated: July 26, 2015

Respectfully submitted by:

Tobin Cooley

Tobin R. Cooley

8000 Offenhauser Dr. #28D

Reno, Nevada 89511
TOBIN R. COOLEY Petition for Exemption pg. 27

APPENDECIES

EXHIBT A: CHEERSON CX-20 AUTO-PATHFINDER USER MANUAL

EXHIBT B: SAMPLE MONTHLY MAINTENANCE LOG
TOBIN R. COOLEY Petition for Exemption pg. 28

EXHIBT A
TOBIN R. COOLEY Petition for Exemption pg. 29
TOBIN R. COOLEY Petition for Exemption pg. 30
TOBIN R. COOLEY Petition for Exemption pg. 31
TOBIN R. COOLEY Petition for Exemption pg. 32
TOBIN R. COOLEY Petition for Exemption pg. 33
TOBIN R. COOLEY Petition for Exemption pg. 34
TOBIN R. COOLEY Petition for Exemption pg. 35
TOBIN R. COOLEY Petition for Exemption pg. 36

EXHIBT B: SAMPLE MONTHLY LOG

MONTHLY MAINTENANCE LOG Month: Year:

CHEERSON CX-20: Serial # - CA0803

ITEM PASS FAIL DESCRIPTION FIXED TECHNICIAN

Fuselage

Wiring

Motors

Rotor Hubs

Propellers

Propeller 

Guards

Landing Skids

Gimbal

Other

YES NO

Updates

Modifications