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** 

**(PU BLIC LAW 112** **- 95)** 

Submitted on July 26, 2015 Tobin R. Cooley 8000 Offenhauser Dr. #28D Reno, Nevada 89511TOBIN 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 27TOBIN 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 LandingTOBIN 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 ofthe FAA Modernization and Reform Act of2012 (FMRA). This exemption will permit SSP to operate an Micro Unmanned Aircraft System (mUAS) for the commercial purpose ofconducting 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 (m UAS) pilot, placing 3rd 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 ofthe four main rotors and the CX
-20 is equipped with autonomous fail safes in the event ofLOL (loss oflink) 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 ofAircraft, 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 ofthe 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). Inconsideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Tobin R. Cooley operation ofthe 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 instr uction manual). Furthermore, Tobin R. Cooley will document and maintain all maintenance records for the Cheerson CX

-20 Auto Pathfinder mUAS. Relieffrom certain requirements of Section 61.113(a) & (b), entitled Privatepilotprivileges 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 pa rticular 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 ofthe Cheerson CX
-20 Auto Pathfinder mUAS within VLOS (visual line ofsight), 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 requirementsforflight in VFR conditions
. Tobin R. Cooley submits that safety will not beTOBIN 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**  **FR OM**  **THE REQUIREMETS**  **OF SECTON**  **61.113. TOBIN**  **R. COOLEY** **’S ARGUMENT**  **FOR EXEMPTON**  **FR OM**  **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 ofthe 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. Ithas 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. Cooleyrespectfully 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 ofbecoming 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 m UAS 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 ofthat 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 ofcertification on those persons, but does not result in a significant safety benefit because the process ofobtaining 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 radio

controlled 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 Inaddition, 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 ofUA 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 ofunmanned 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 athttp://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.7 Finally, 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 ofthis 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 ofsafety 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 F ROM 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 of49 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 forwhich 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 spor t 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 ofTitle 49. Exemption No. 11110 at 14. This argument ignores the plain language ofthe 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.
-Inmaking the determination under subsection (a), the Secretary Shall determine, at a minimum

- (1) which types ofunmanned aircraft systems, if an, as a result oftheir 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 threatto national security; and (2) whether a certificate ofwaiver, certificate ofauthorization, or airworthiness certification under section 444704 oftitle 49, United States Code, is required for the operation ofunmanned 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. Ifthe 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 of49 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. Ifthere 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, entitledAltimeter settings, subsection (a), states the following, in part: (a) Each person operating an aircraf t 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) Ifthere is no station within the area prescribed in paragraph (a)(1)(i) ofthis 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 requirementsforflight in VFR conditions, subsection (b), states the following: (b) Noperson may begin aflight in a rotorcraft under VFR conditions unless (considering wind andforecast weather conditions) there is enoughfuel tofly to thefirstpoint ofintended 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, entitledMaintenance 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) Ithas been approved for return to service by a person authorized under § 43.7 ofthis chapter.TOBIN R. COOLEY Petition for Exemption pg. 12

**7. TOBIN**  **R. COOLEY**  **SEEKS EXEM** **PTION FROM**  **THE REQUIREMENTS**  **OF SECTIONS 91.409(a)(1) and 91.409(a)(2).**  Section 91.409, entitledInspections, subsection (a), states the following: (a) Except as provided in paragraph (c) ofthis 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 ofan 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, entitledMaintenance 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) ofthis 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 oflife

-limited parts ofeach 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 recu rring action, the time and date when the next action is required. vi) Copies ofthe forms prescribed by § 43.9(d) ofthis 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) ofthis 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) ofthis section shall be retained and transferred with the aircraft at the time the aircraft is sold. 3) A list ofdefects furnished to a registered owner or operator under § 43.11 ofthis 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. E** **XTENT 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 reliefis 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 ofthe Cheerson CX
-20, conducted by the PIC pursuant to the grant ofthis 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 reliefbecause 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.**  **COOLE Y**  **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 ofthe 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) entitledFuel requirements for flight in VFR conditions, is requested to the extent required to allow flights ofthe 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 ofintended landing and, assuming normal cruising speed, to fly after that for at least 2 minutes. Tobin R. Cooley seeks the requested reliefbecause 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 relieffrom 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 CX

20 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 ofconstruction 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**  **PU BLIC**  **WILL BEBEFIT**  **FR OM**  **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 takeoffor land. Likewise, a reduction ofmanned 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 PU** **BLIC WILL**  **BENEFIT FROM**  **THE SAFETY**  **AND EFFICIENCY**  **OF THE**  **CHEERSON CX -** **20 mUAS.** Conducting aerial acquisitions with the Cheerson CX
-20 mUAS, instead ofmanned 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 leadedTOBIN 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 of20 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.**  Inaddition 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 ofthe 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, com panies 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

Inconsideration 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 ofFMRA 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 ofthis subtitle, and not later than 180 days after the date ofenactment ofthis 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 ofunmanned aircraft systems, ifany, as a result oftheir size, weight, speed, operational capability,proximity to airports andpopulated areas, and operation within visual line ofsight do not create a hazard to users ofthe national airspace system of the public or pose a threat to nationalsecurity; and 2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is requiredfor the operation of unmanned aircraft systems identified under paragraph (I). (c) Requirementsfor Safe Operation.

— Ifthe 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 ofthe 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**  **mUA S**  **IS EQUIPPED**  **WITH AUTO** **NOMOU S**  **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 ofa loss oflink (LOL) with the ground control station (GCS) the Cheerson CX
20 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**  **WI LL**  **BE CONDUCTED**  **PURSUANT TO**  **SPECIFIC OPERATING LIMITATIONS.** In seeking this exemption, Tobin R. Cooley proposes to commercially operate the Cheerson CX
20 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 ofno 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 m

UAS 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. Ifa 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. Itis 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 ifit 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 ofthe 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 ofoperations. 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 ofagreement 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 off icial 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 ofthe 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 cond ucted 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 FR** **OM TH**  **REQUIREMENTS OF**  **SECTION 61.113(a)**  **AND (b) WOULD NOT ADVERSELY AFFECT SAFETY.** Tobin R. Cooley submits that the equivalent level ofsafety 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 ofoperations, and the airmanship skills necessary to safely operate the Cheerson CX
-20 mUAS, Tobin R. Cooley submits that the additional mannedTOBIN 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 of5 hours ofthose 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 f light 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 Exem ption No. 11062, the PIC must also have accumulated and logged a minimum of5 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 ofmulti

rotor 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 cond uct 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 ofsafety 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 SA FETY.**  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 ofsafety 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 relieffrom 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 ofthe 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 relieffrom 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 FR** **OM 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 CX

20 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. Inconsideration of Tobin R. Cooley’s proposed operating limitations, the operating documents, and the technical aspects ofthe 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

Inaccordance 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 ofthe mUAS for the limited purpose of conducting aerial video and photography over certain areas ofthe United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe 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 ofthe 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: Ifthe FAA finds that the airworthiness regulations ofthis 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 exemptionfrom the requirements of14 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 O** **F 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 cond

ucting 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 89511TOBIN R. COOLEY Petition for Exemption pg. 27 **APPENDECIES**

**EXHIBT A:** CHEERSON CX
-20 AUTO
-PATHFINDER USER MANUAL **EXHIBT B:** SAMPLE MONTHLY MAINTENANCE LOGTOBIN R. COOLEY Petition for Exemption pg. 28 **EXHIBT A**TOBIN R. COOLEY Petition for Exemption pg. 29TOBIN R. COOLEY Petition for Exemption pg. 30TOBIN R. COOLEY Petition for Exemption pg. 31TOBIN R. COOLEY Petition for Exemption pg. 32TOBIN R. COOLEY Petition for Exemption pg. 33TOBIN R. COOLEY Petition for Exemption pg. 34TOBIN R. COOLEY Petition for Exemption pg. 35TOBIN 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