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September 6 , 2015

U.S. Department of Transportation
Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591

Re: Petition for Exemption under Section 333

To whom it may concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Courtright Aerial Services , LLC (hereinafter referred to as “ CAS ”) seeks an exemption from the Federal Aviation Regulations ( FARs ) listed below and discussed in Appendix

A to allow for commercial operations of small unmanned aircraft systems (sUAS)

.

This exemption will allow CAS to safely operate sUAS under controlled conditions in the National Airspace System (NAS) for the purposes of acquiring data for a erial photography and videography

, precision agriculture, education

, inspection, search and rescue

, survey and mapping, sUAS training and research and development. The proposed operations would permit the use of sUAS under controlled conditions in predetermined airspace that provides an increased level of safety beyond that existi ng when manned fixed or rotary wing aircraft are used to accomplish the same purpose. The FAA can be assured that the proposed UAS operations will be conducted at an equivalent or greater level of safety.

CAS proposes to use the following sUAS platforms for operation under this request:

1. DJI Phantom 3
2. DJI F450
3. Turbo Ace Matrix
4. Tarot T960

Each of these platforms weigh less than 55 pounds , including energy sources and equipment.
Each UAS consists of a lightweight battery powered aircraft, associated video and communications equipment , and a computer

- based ground control station

. All platforms are
controlled via either DJI Naza

- M V2 or Pixhawk flight control systems which will always be used in fail safe mode. The fail safe mode ensures that when there is a low voltage scenario, or when loss of radio communication takes place the sUAV will return to its point of takeoff and land. All platforms have a GPS position hold installed in them. If for any reason the ope rator stops2 | P a g e

inputting direction into the controller the s UAV will hold its position until further input is provided insuring the aircraft will not fly away from its desired position.

In accordance with th e FAAs UAS Integration office’s guidance, each of these sUASs will be registered with the FAA. Prior to any UAS o peration, the Pilot in Command ( PIC ) will ensure a NOTAM is properly filed, the weather exceeds all minimum conditions, all pre

- flight checks are complete and that UAS performance is satisfactory for flight in the NAS.

Below is a summary of operational limitations and conditions that will ensure CAS operate s at an equivalent or higher level of safety for each regulation requiring an exemption:

1. CAS will obtain an Air Traffic Organization (ATO) issued Certificate of Authorization (COA) prior t o conducting any UAS operations grant of exemption.
2. All UAS operations will be conducted in accordance with the parameters prescribed in the approved COA.
3. The sUAS will weigh less than 55 pounds including energy sources and equipment.
4. The sUAS will be flown at speeds not to exceed 5 0 knots.
5. Flights will be flown at an altitude of no more than 400 feet AGL.
6. sUAS operations will only be conducted during daylight hours under VFR conditions.
7. The PIC will possess at l east a sport pilot certificate and hav e either a current FAA medical certificate or valid U.S. driver’s license.
8. The sUAS will be operated within visual line of sight (VLOS) of the PIC at all times.
9. The sUAS will not be operated less than 500 feet below or less than 2,000 feet horizontally f rom a cloud or when visibility is less than 3 statute miles from the PIC.
10. All operations will utilize a visual observer (VO) who will maintain verbal communication with the PIC at all times.
11. The PIC will operate the sUAS from a stationary position and not from a moving device or vehicle.
12. The PIC will ensure that the sUAS remains clear and yield the right of way to all manned operations and activities.
13. Flights will be conducted at a lateral distance of at least 100 feet away from inhabited structures, buil dings, vehicles, vessels, and any people not associated with the UAS operation.
14. Prior to each flight, the PIC will inspect the UAS to ensure that it is airworthy to operate safely in the NAS.
15. CAS will follow each manufacturer’s sUAS maintenance, overhaul, replacement, inspection and life limit requirements.
16. Maximum total flight time for each operational flight will be limited to the amount of time the UAS can be flown and still maintain reserve battery power of no less
than 25%.
17. All documents req uired by 14 C.F.R sections 91.9 and 91.203 will be available to the PIC at the sUAS ground station any time the sUAS is operating.
18. Any incident, accident or UAS operation that exceeds the lateral or vertical boundaries of the operational area as defined b y the approved COA, will be reported3 | P a g e to the FAA’s UAS Integration Office (AFS

- 80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) in accordance with the NTSB guidance.

CAS submits that grant of this exemption application for commercial sUAS use will advance the Congressional man date in Section 333 of the Reform Act to accelerate the introduction of sUASs into the NAS if it can be accomplished safely. This law directs the Secretary of Transportation to consider whether certain sUASs may operate safely in the NAS before completion of the rulemaking required under Section 333 of the Reform Act. In making this determination, the Secretary is required to determine which types of sUASs do not create a hazard to users of the NAS or the public or pose a threat to national security in ligh t of the following:

● The sUAS’s size, weight, speed, and operational capability; ● Operation of the sUAS in close proximity to airports and populated areas; and ● Operation of the sUAS within visual line of sight of the operator.

Reform Act § 333(a)(1). If the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. §333(c).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under §40101 of the Act, from the requirement that all civil aircraft must have a current airwort hiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial

service:

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of se ctions 4470244716 of this title if the Administrator finds the exemption is in the public interest.

49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1).

The grant of the requested exemption is in the public interest based on the clear direction in Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; the stro ng equivalent level of safety surrounding the proposed operations; and the significant public benefit, including enhanced safety and cost savings associated with transitioning to sUASs for commercial use. Accordingly, the applicant respectfully requests th at the FAA grant the requested exemption without delay

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The name and address of the petitioner is : Cou rtright Aerial Services, LLC

Attn: Nick Courtright
Ph: 614

- 397

- 0558
Email : N.Courtright@gmail.com
Address: 5809 Kean Rd. Westerville, Ohio 43082

The regulations from which the exemption is requested are as follows:

 14 CFR Part 21

 14 CFR 45.23

 14 CFR 61.11 3 (a) & (b)

 14 CFR 91.7(a)

 14 CFR 91.9(b)(2)

 14 CFR 91.103

 14 CFR 91.109

 14 CFR 91.119

 14 CFR 91.121

 14 CFR 91.151(a)

 14 CFR 91.203(a) & (b)

 14 CFR 91.405(a)

 14 CFR 91.407(a)(1)

 14 CFR 91.409(a)(2)

 14 CFR 91.417(a)

Appendix A discusses each rule listed above and explains why exemptions pursuant to the proposal set forth in this letter are appropriate, provide an equivalent level of safety, and are in the public interest.

S incerely, Nick Courtright Courtright Aerial Services

Appendices:
A. EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY
B. SUMMARY OF CAS SECTION 333 EXEMPTION REQUEST
C. sUAS OPERATORS MANUALS5 | P a g e

APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY

CAS requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the above mentioned sUASs :

14 CF R Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1) Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requiremen ts for the issuance of airworthiness certificates as required by FAR § 91.203(a)(1). Given the size , weight, speed, operational capability of the particular sUASs it i s unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H to achieve or exceed current safety
levels.

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and

Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both
authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airpo rts and populated areas of the sUAS involved.

In this case, an analysis of these criteria demonstrates that the CAS ’s sUAS platforms operated
without a n airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness
certificate. The sUAS platforms to be operated by CAS will all weigh less than 55 pounds

. They
will not carr y a pilot or passenger, will not carry f lammable fuel, and will operate exclusiv ely within an area pre

- disclosed and in compliance with conditio ns set forth herein. Operations under this exemption will be tightly controlled and monitored by both the operat or, p ursuant to the conditions set forth above, and by local public safety requirements. T he FAA will have
advance notice of all operations through the filing of NOTAMs. The size of the aircraft, the lack of flammable fuel, and the fact that the aircraft i s carried to the location and not flown there all establish the equivalent level of safety. CAS ’s sUAS platforms provide at least an equi valent, and most likely exceeds, level of safety to that of such operations b eing cond ucted with
conventional aircraft that would be orders of magnitude larger an d would be carrying

passengers, cargo, and flammable fuel. The automated safety features d ocumented in the

m anufacturer

- provided manuals highlight the d esign intentions towards safety and reliability of

CAS ’s sUASs

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14 CFR 45.23 & 91.9 (c): Marking of the Aircraft Regulation 45.23 provides: (a) Each operator of an ai rcraft must display on that aircraft marks consisting of the Roman capital letter “N” (denoting United States registratio n) followed by the registration number of the aircraft. Each suffix letter used in the marks displayed must also be a Roman capital let ter. (b) When marks include only the Roman capital letter “N” and the registration number is displayed on li mited, restricted or light

- sport categ ory aircraft or experimental or provisionally certificated aircraft, the operator must als o display on that ai rcraft near each entrance to the cabin, cockpit, or pilot station, in let ters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted, ”light

- sport,” “experimental ,” or “provisional,” as applicable.

Regulation 91.9(c) provides : No person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter.

The s UAS platforms that CAS will operate have no entry point s to a cabin, cockpit, or pilot
station on whi ch these markings stated above could be placed. In addition, due to the small size
of the s UAS s , 2 inch lettering is not possible. CAS is prepared to mark the sUAS with the name of the organization and location or origin and fulfi ll any other request by the FAA to this topic in accordance to § 45.29(f) where the pilot, observer, and others working with the sUAS will see
the identification of the sUAS.

The FAA has issued the following exemptions to this regulation, see Exemption No s. 8738, 10167, 10167A

, and 10700.

14 CFR § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command Part 61.113 (a) & (b) limits private pilot privileges to non

- commercial operations. Unlike a conventional aircraft that carries a pilot, passengers or cargo, the sUAS is remotely controlled and carries no passengers or property. All sUAS flight s will be planned and coordinated in advance and the operations area will be controlled. The level of safety provided by the above mentioned operational limitations and the m anufacturer i nstructions exceeds that provided by an individual holding a commer cial pilot’s certificate operating a conventional aircraft. Because the sUAS carries no pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC to have a t least a sport pilot’s

cert ificate rather than a commercial pilot’s certificate to operate the sUAS.

14 CFR § 91.7(a): Civil aircraft airworthiness. This regulation requires that no person may operate a civil aircraft unless it is in an airworthy condition. As there will be no airworthiness certificate issued for the sUAS, should this exemption be granted, as no FAA regulatory standard exists for de termining sUAS7 | P a g e

airworthiness. An equivalent level of safety will be provided by the small size of the sUAS and the requirements contained in the m anufacturer i nstructions for maintenance and use of safety checklists prior to flight. CAS will en sure that the sUAS is in an airworthy condition prior to each flight based on compliance with the specifications in the flight operations manual and the

m anufacturer’s i nstructions.

14 CFR § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. CAS ’s s UAS s are small and will not carry any passengers. An equivalent level of safety will be accomplished by keeping the flight manual at the ground
control station wh ere the PIC will have immediate access to it during all flights. The FAA has issued to others the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 CFR § 91.103: Preflight action
Th is regulation requires each PIC to take certain actions before flight to ensure safety of flight. As FAA approved flight manuals will not be provided for the sUAS, an exemption from this regulation is required. An equivalent level of safety will be provide d by the PIC following the procedures set forth in the m anufacturer’s i nstructions. The PIC will take all actions including reviewing weather, flight battery, takeoff and landing distances and aircraft performance data before initiation of the flight. The PIC will also account for site specific conditions in their preflight actions.

14 CFR § 91.109 Flight Instruction This regulation provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instructio n unless that aircraft has fully functioning dual controls. sUAS by their design, typically do not have functional dual controls. Given the size and speed of the sUAS, an equivalent level of safe training can be performed without dual controls because no p ilot or passengers are aboard the aircraft and all persons will be a safe distance away in the event the sUAS experiences any difficulties during the flight instruction.

14 CFR § 91.119: Minimum Safe Altitudes
Section 91.119 establishes safe altitudes fo r operation of civil aircraft. Section 91.119(d) allows helicopters to be operated at less than the minimums prescribes, provided the person operating the helicopter complies with any routes or altitudes prescribed for helicopters by the
FAA. As this exem ption is for sUAS that are similar to helicopters, and the exemption request authority to operate at altitudes up to 400 ft AGL, an exemption may be needed to allow such operations. The sUAS will not be operated above 400 ft AGL. The equivalent level of sa fety will be achieved given the size, weight and speed of the sUAS as well as the location of operation.
The low

- altitude operations of the sUAS will ensure separation between the sUAS and operations of conventional aircraft that must comply with 91.119.8 | P a g e

14 CFR § 91.121: Altimeter Settings This regulation requires that each person operating an aircraft shall maintain the cruising altitude by reference to an altimeter that is set “to the elevation of the departure airport or an appropriate altimeter setting available before departure.” An exemption is required as the sUAS do not have a barometric altimeter, but instead have GPS altitude read out. An equivalent level of safety will be achieved by the PIC confirming the altitude of the launch site shown on

GPS altitude indicator before flight.

14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions The regulation provides that no person may begin a flight in an airplane under day

- VFR
conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. An equivalent level of safety will be achieved due to operations being conducted on site without significant transit time by the sUAS. The maximum total flight time for each flight will be limited to the amount of the sUAS can be flown and still maintain a reserve battery power or fuel quantity of no less than 25%. The FAA has granted similar exemptions to others, including Exemptions 2689F, 5745, 10673 and 10808.

14 CFR § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration This regulation provides as follows: (a) ... no person may operate a civil aircraft unless it has ... an appropriate and current
airworthiness certificat e. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.7 15 is displayed at the cabin or cockpit entrance so that it is legible to passe ngers or crew.

The sUAS platforms weigh no more than 55 pounds fully loaded and are operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them. An equivalent level of safet y will be achieved by keeping these documents at the ground control station where the pilot flying the sUAS will have immediate
access to them.

The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 CFR § 91.405(a); 407(a)(1); 40 9(a)(2); 417(a): Maintenance Inspections Section 91.405(a) requires that an aircraft operator or owner “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 ...” Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the issuance of an air worthiness certifi cate. Section 91.417(a) requires the owner or operator to keep records showing certain maintenance9 | P a g e

work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service.

Maintenance and inspections will be performed in accordance with the sUASs u ser’s m anuals, therefore ensuring an equivalent level of safety. CAS wil l perform required maintenance, keep a log of any maintenance performed, and the operator w ill confirm that the sUAS is in working order prior to initiating flight. The operator is th e person most familiar with the aircraft and
best suited to maintain the aircraft in an air worthy condition to provide the equivalent level of safety. Due to the sUASs size and carry ing capacity, and the fact that flight operations will only take place in restricted areas for limited per iods of time, if a mechanical issue arises it creates less risk than that associ ated with conventional aircraft performing the same operation.10 | P a g e

APPENDIX B

SUMMARY OF CAS SECTION 333 EXEMPTION REQUEST

CAS hereby provides pursuant to Part 11 a summary of its exemption application to allow
commercial operation of the above referenced sUASs . An exemption is requested from the following regulations:

 14 CFR Part 21

 14 CFR 45.23

 14 CFR 61.113 (a) & (b)

 14 CFR 91.7(a)

 14 CFR 91.9(b )(2)

 14 CFR 91.103

 14 CFR 91.109

 14 CFR 91.119

 14 CFR 91.121

 14 CFR 91.151(a)

 14 CFR 91.203(a) & (b)

 14 CFR 91.405(a)

 14 CFR 91.407(a)(1)

 14 CFR 91.409(a)(2)

 14 CFR 91.417(a)