January 15, 2016 U. S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590 

### RE: Petition CP PRODUCTIONS LLC for Exemption Pursuantto Section 333 ofthe FAA Reform Act Petitioner's Name andAddress: CP PRODUCTIONS LLC Owner: Herbert CStackhouse 166 Hurffville Cross Keys Rd. Sewell, NJ 08080 856-449-7349 chris@cpwebmarketing.com To whom it may concern: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, CP PRODUCTIONS LLC operatorofSmall Unmanned Aircraft Systems ("UASs") equipped to conduct aerial photography and videography, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of UASs, so long as such operations are conducted within and underthe conditions outlined herein or as may be established bythe FAA as required by Section 333.1 As described morefully below, the requested exemption would permit the operation ofsmall, unmanned and relatively inexpensive UAS under conditions in airspace that is 1) limited 2) predetermined and 3) controlled. The proposed exemption, ifgranted, would allow CP PRODUCTIONS LLC to conduct commercial operations of UASs meeting or exceeding all of the operational and safety requirements Congress has set forth in Section 333. CP PRODUCTIONS LLC plans to use the capabilities of UASs to offer a multitude ofservices, including:

- Insurance surveys and inspections

- Real Estate Photography and presentation

- Construction site inspections and monitoring -Event Photography/Videography

- Aerial filmmaking and photography -Aerial surveying oflocal water supplytothe community

- Agriculture and Livestock monitoringStatutoryAuthority Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems", provides a mechanism for seeking expedited FAA authorization ofsafe civil Unmanned Aircraft Systems (UAS) operations in the National Airspace System ("NAS"). Section 333(a) states that the FAA "shall determine ifcertain unmanned aircraft systems may operate safely in the national airspace system before completion ofthe (comprehensive) plan and rulemaking required by section 332(b)(1) ofthis Act orthe guidance required by section 334 ofthis Act." In Section 332(b)(1), Congress made it clearthat Section 333 provides a mechanism for "expedited operation authorization" ifseveral factors are met. Petitioner meets all requirementsto permit FAA approval ofcommercial UAS operations. The name and address ofthe applicant are: Name: Owner: Address: Phone: Email: CP PRODUCTIONS LLC Herbert Stackhouse 166 Hurffville Cross Keys Rd. Sewell, NJ 08080 856-449-7349 chris@cpwebmarketing.com Regulations from which the exemption is requested: 14C.F.R. Part 21 14C.F.R. 45.23 (b) 14 C.F.R. 61.113(a) and (b) 14C.F.R. 61.315(c) 14C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b)(2) 14C.F.R. 91.109 14C.F.R. 91.119 14 C.F.R. 91.121Page 3 14 C.F.R. 91.151(a) 14 C.F.R. 91.203 (a) 

### & (b) 14 C.F.R. 91.205 (b) 14 C.F.R. 91.215 14 C.F.R. (91.401- 91.417) UASs are oftentimes seen as superiorto helicopters duetothe lesser cost ofequipment, the reduction of personnel needed to operate equipment, reduced noise levels and zero emissions intothe environment. In addition to providing cost savings and having littleto no impact on the environment, UASs provide enhanced safety. These factors are beneficial for, and in the best interest of, the public. Accordingly, the applicant respectfully requests thatthe FAA grantthe requested exemption without delay. Petitioner is requesting an exemption to enable CP PRODUCTIONS LLC to operate a DJI Inspire 1 UAS, as well as a DJI Phantom 3. Both always upgraded to latestversion firmware, equipped with a 3 axis Zenmuse camera gimbal, which uses a High-Defvideo camera that can capture upto 4K (4096x2160p) video and 12M pixel photos. Both ofthese UAS vehicles have a built-in capabilityto limit 1) the height itflies above the ground and 2) the radius ofthe distance itflies from the operator. The OJI Inspire 1and Phantom 3 also has thefailsafe function ofthe autopilot system, which means, when the communication between the Main Controller and the transmitter is disconnected, the outputs ofall command sticks from controller will go tothe center position

. Ifthe GPS signal is good enough, the system will automaticallytrigger Return to Home and will land safely. Both ofthese aircrafts have atotal gross weight of less than 7 pounds when fully equipped. A pre-flight inspection will be performed by the PIC in accordance with thefactory instruction manual, as well as redundant checks to include the Internal Measurement Unit (IMU) to make sure thatthe compass, gyro and acceleration values are within specs, positive GPS locks are secure, battery health in each individual LiPo cells are balanced, and radio signals are locked in

. The UAS will be maintained in accordance with the manufacturer's instruction manual and only manufacturer's authorized replacement parts will be used.


### FCC Information The OJI Inspire 1 and Phantom 3 transmitters used for controllingthe UAS comply with part 15 ofthe FCC rules

. Operation is subject tothe following two conditions: (1) This device may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation. The radio transmitters ofthe DJIInspirel and Phantom 3 used for controllingthe UAS is wireless technology which has been tested and found to be compliant with the applicable regulations governing a radio transmitter in the 2.400GHz to 2.4835GHz frequency range. 

### Antenna Separation Distance When operatingthe OJI Inspire 1or Phantom 3transmitter, the PIC will maintain aseparation distance ofat least 5 em between his body (excludingfingers, hands, wrists, ankles and feet)

. and the antenna to meet RF exposure safety requirements as determined by FCC regulations. 

### Pilot in Command and Observer Qualifications and Duties The PIC will maintain at least aSport Pilot Certificate and a current State issued driver's license, plus at least 2 hours flying time and 3takeoffs and landings within 30 days in thetype of UAS utilized in operations. The PIC will have at least 30 hours flying Radio Controlled Model Aircraft, ofwhich, 10 hours will be flying UASs. The PIC is responsible forthe safe and efficient operation ofthe aircraft

. Specific duties include all preflight preparation and inspection, in flight operation, post flight requirements, and all procedures including but not limited to: 

## .,• Safe in flight operations • Risk evaluation • Current weather conditions for safe flight The Observer must have the visual acuity to observe the UAS and be able to communicate clearly with the PIC. The Observers duties are:

• Warning the PIC ofany impending obstacles in the flight path ofthe UAS

. • Warning the PIC ofany deviations in the planned flight path ofthe UAS. • Warningthe PIC should any unauthorized personnel appear in the area ofthe planned flight. The Observer will have the authorityto orderthe PIC toterminate the flight should he feel the flight cannot be conducted safely

. 

### General Operating Standards
• CP PRODUCTIONS LLC will only operate its UAS in line ofsight ofa pilotand/or observer and will operate at sites that are a 'sufficient distance' from populated areas. Such operation will insure thatthe UAS will "not create a hazard to users ofthe national airspace system orthe public

."
• Before an operation ofa UAS within SNM ofan airport with a control tower, the control tower will be called to gain permission to operate the UAS. The PIC will give the position, altitude and thetimes the UAV will be operated. The UAS will not be operated at an altitude ofover 200 feet AGL. Weather minimums will be 3 miles visibility and a 1000foot ceiling.
• Before an operation ofa UAS within SNM ofa non-tower controlled, airportoperators will be notified and the PIC will give the right ofwayto avoid flying in the proximity of full-scale aircraft

. At notime will the UAS be operated within thefinal approach course
. and the takeoff course ofany runway. The UAV will not be operated at an altitude of over 200 feet AGL. Weather minimums will be 3 miles visibility and a 1000foot ceiling

. • Maximum flight timefor each operational flight will be 18 minutes.
• Flights will be terminated at 30% battery power reserve should that occur priorto the 18 minute limit

. • The UAV will be programmed so that itwill not be operated at an altitude of more than 200 feet AGL, and not more than 200 feet above an elevated platform from which filming is planned.
• Minimum crew for each operation will consist ofthe UAS Pilot, and Visual Observer. 

### .,• The UAV operated by the petitionerweighs less than 55 pounds, includingthe payload (i.e

. camera, lens, and gimbals).
• The UAS will operate at speeds much less than 87 knots, can hover, and can simultaneously move vertically and horizontally.
• Given the small size ofthe UAV and the restricted sterile environmentwithin which theywill operate, our UAV operations adhere to the Reform Act's safety requirements

.
The UAS, powered by batteries, is smaller, lighterand more maneuverable than larger aircraft running on combustible fuel. The UAS operates at lower altitudes with no people on board and will thereby reduce current risk levels, enhance safety and diminish the likelihood ofdeath or serious bodily injury. With asmall payload and maximum flighttime ofonly 18 minutes, this offers little or no risk to national security

. Low level oblique photos and video from several angles are far more effective than ground based imageryfor displayingthe characteristics of large, complex properties with several buildings and large trees. The benefits of reduced cost and improved quality ofpresentation from the UAS over manned aircraftwill be valuable to and benefit many buyers and sellers of real property, farmers and ranchers, and local city officials to monitorour local water supply.



### EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY CP PRODUCTIONS LLC requests an exemption from the following regulations as well as any additional regulations that maytechnically apply tothe operation ofthe UAV System: 

### 14 CFR Part 21, Airworthiness Certificates This part establishes the procedures forthe issuance ofan airworthiness certificate. While the FAA continues to workto develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued forthe DJIInspire1 and Phantom 3 undereither or both ofthe following provisions: 21.191 Experimental certificates

. Experimental certificates are issued forthe following purposes: 

### (a) 

### Research anddevelopment. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operatingtechniques, or new uses for aircraft

. 

### (b) 

### Showing compliance with regulations. Conducting flight tests and otheroperations to show compliance with the airworthiness regulations includingflights to show compliance for issuance oftype and supplemental type certificates, flights to substantiate majordesign changes, and flights to show compliance with the function and reliability requirements ofthe regulations

. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crewtraining, we would expect thatan experimental certificate would permit ourcommercial purpose as well. The aircraft will notcarry persons orproperty, will not carryfuel, and will onlyfly under strict operational requirements. Combined with the UAS's light weight, being constructed primarily ofcarbon fiber and plastic, we propose that the UAS will be at least as safe, ifnotsafer, than aconventionally certificated aircraft performingthe same mission. Ifan experimental airworthiness certificate is not appropriatefor this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citingthe equivalent level ofsafety outlined in the previous paragraph. 

### 14 CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high

.Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high nearthe entrance tothe cabin, cockpit, or pilot station. The UAS does not have an entrance in which the word "EXPERIMENTAL" can be placed. We propose to achieve an equivalent level ofsafety by includingthe word "EXPERIMENTAL" on thefuselage, where the PIC (Pilot In Control), VO (Visual Observer) and others in the vicinity ofthe aircraft while it is preparing for launch will be able to see the designation. All aircraft operated in accordance with the granted exemption will be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N-Number) markings in accordance with 14 CFR part45, Subpart 

### C. Markings will be as large as practicable. 

### 14 CFR 61.315 Whatare the limits and privileges of my sport pilot certificate, 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. 61.315 subparagraph (c) does not allow a person who holds a Sport Pilot Certificate to act as a Pilot in Command in furtherance ofa business. 61.113 providesthat no person that holds a Private Pilot certificate may act as Pilot in Command ofan aircraft for compensation or hire. Subparagraph (b) allows a private pilotto act as pilot in command ofan 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 propertyfor compensation or hire. Our proposed operations require that the PIC must hold at least aSport Pilot Certificate

. with a current valid U.S. driver's license issued by a state, the District ofColumbia, Puerto Rico, aterritory, a possession, orthe Federal government and is activelytrainingtowards earning a Private Pilot Certificate with a Class Ill Medical issued bythe FAA. Since the aircraft cannot carry passengers or property, wefeel we meetthe intent of61.113 Subparagraph (b) even though the intent ofthis application is to conduct a business and are entitled to relieffrom 61.315 (c) in consideration ofthe guidelines set forth in the granted exemptions of previous petitioners in similar circumstances. 

### 14 CFR 91.7 Prohibits the Operation ofan aircraftwithout an airworthiness certificate. As no such certificate will be applicable in theform contemplated bythe FARs, this Regulation is inapplicable.

### 14 CFR 91.9 Civil aircraftflight manual, marking, and placard requirements. This regulation provides that no person may operate an aircraft unless acurrent, approved flight manual is in the aircraft. We assume thatthe intent ofthis requirement is to ensure that flight manual information is available tothe aircrew while operatingthe aircraft. We request an exemption to this requirement since the aircraft is not onlytoo small to carry documentation, the documentation would not be available tothe crew duringflight operations. To obtain an equivalent level ofsafety and meet the intent of91.9, we propose that a current, approved UAS Flight Manual must be available to the crew atthe ground station anytimethe aircraft is in, or preparing for, flight, and ready for presentation for any governing official upon request. 

### 14 CFR 91.109 Flight Instruction; Simulated instrumentflight and certain flight tests The regulation states that "No person may operate a civil aircraftthat is being used forflight instruction unless that aircraft has fully functioning dual controls. Although the DJIInspire 1 is capable ofduel/linked controls, CP PRODUCTIONS LLC will be operating with asingle remote controller. 

### 91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feetto any person, vessel, vehicle, orstructure. Since thetypical mission ofthe UAS would be photography orsurvey ofpersons, vessels, vehicles orstructures it would be necessaryto operate closer than 500 feettothe items listed. Operations will only be flown over propertyor persons where permission has been obtained and careful preplanned flight path has been performed. The aircraft will be operated at a low altitude allowing, ifa power unitfails, an emergency landing without undue hazard to persons or propertyon the surface. Therefore we maintain that due tothe small size ofthe UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption. 

### 14 CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM ofthe aircraft. The UAS will always fly below 200 feet AGL and will not need to maintain cruising altitudes in orderto prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the UAS on-board computerto the display screen held by the PIC, providing a constantly updated AGL readout. 

### 14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no person may begin aflight in an airplane under day-VFR conditions unless there is enough fuel toflytothe first point of intended landing and to fly after that for at least 30 minutes. We feel the intention ofthis paragraph is to provide an energy reserve as a safety bufferfor delays to landing. The UAV is battery operated and the maximum duration offlight from asingle battery charge is 18 minuteswith a 30% reserve. Since theaircraftwill neverfly more than 0.263 NM from the point of intended landing, afull battery charge at launch will ensure thatwe meetthe reserve energy requirement ofthis paragraph. We request an exemption to theword "fuel" and ask for an equivalent interpretation with the word "energy". 

### 14 CFR 91.203(a) 

### &(b) Civil aircraft: Certifications required. The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides thatthe airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers orcrew
." At a maximum gross weight of6

.47 pounds, the UAS is too small to carry documentation, does not have an entrance, and is not capable ofcarrying passengers or crew. To obtain an equivalent level ofsafety and meetthe intent of91.203, we propose that documents deemed appropriateforthis aircraft bythe FAA will be with the crew atthe ground control station and available for inspection upon request. In orderto identify the aircraft, we propose thatthe information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23. 

### 14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations The regulation provides thatthe operator is primarily responsible for maintainingthe aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require thatthe aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our intentionthat the PIC perform maintenance and inspection ofthe aircraft and "be authorized to approve theaircraftfor return to service." The PIC will ensure thatthe aircraft is in an airworthycondition priorto every flight and in addition conduct detailed inspections aftereverytwo hours offlight. Maintenance performed by the PIC is limitedto repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware forthe on-board computer. All other maintenancewill be performed by the manufacturer ortheir designated repairfacility

.The PIC will document work performed in accordance with 91.417. We feel that dueto the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level ofsafety

. 

### Safety and Benefits ofthe UAS CP PRODUCTIONS LLC will be using the UAS in avariety ofapplications that generally require expensive full-size manned aircraftto complete. Small, light, unmanned aerial vehicles offer more efficient and safer benefitsoverthe use offull-sized manned aircraft for aerial photography, advanced agriculture monitoring, film and still photography, real estate marketing, inspection ofbuildings and transportation infrastructure Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no passengers or crew creates a much greater margin ofsafetyforthe pilots, crew and general public.By granting CP PRODUCTIONS LLC's requested exemptions, the FAA will help drive development ofsafe and successful commercial UAS operations and will advance the public knowledge base for such operations. CP PRODUCTIONS is committed to promotingthe UAS research efforts of policymakers includingthe FAA, NASA, DOD and DARPA bysharing data from its commercial UAS operations and serving as a resource forfuture UAS research operations. Thus, the FAA has good cause to grantthis Petition. 

### Conclusion As pointed out in this application, the DJIInspirel and Phantom 3, which our company would 

### use, under authorization by the US DOT-FAA, are small, light-weight devices operated within the line ofsight ofthe Pilot-in-Command (PIC), less than 200 feet above the ground and outside 5 miles from any airport, heliport, seaplane base, spaceport, or other location with aviation activities, unless the airtraffic control authorities (ATC) have been notified and have authorized each flight within a radius ofthis distance. The DJIInspirel and Phantom 3 both have been proven capable for controlled flight. Both are a UAS offered for general sale on the market around the world and have often been used as Model Aircraft in the USA. We are certain thatthe studies conducted until now bythe FAA, about Section 332, Public Law 112-95, 2014, have already provided you with the assurances on the airworthiness of UAS such as ours. For the foregoing reasons, the exemptions requested herein should be granted and CP PRODUCTIONS LLC should be permittedto conduct small UAS operations in accordance with its manuals and all otheroperating parameters deemed necessary and appropriate bythe FAA. The submission ofthis application and its contents is the best demonstration that indeed it is possible to pursue the authorization process so that some UAS may be used for legitimate commercial activities and under reasonably safe conditions. Signed



# ~k£~ Herbert Stackhouse CP PRODUCTIONS LLC