Docket Operations, M-30 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Room W12-140, West Building Ground Floor 

Washington, DC 20590-0001 

October 15, 2015 

)1J ' 5- l9tt'6' 

Re: Exemption Petition Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

Dear Sir /Madam, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, 

Thomas Cogan (Applicant) hereby applies for an exemption from the listed Federal Aviation 

Regulations (FAR) (Attachment 1) to allow operation of small Unmanned Aircraft (UA) under the 

conditions outlined herein or as may be established by the FAA as required by Section 333 to allow 

for commercial aerial imaging and video production operation. 

The attachments include: (1) Exemptions Requested, (2) Operational Restrictions and Limitations, (3) 

Benefits to Public Interest, and ( 4) the Specification for the DJI Inspire 1 Model T600 UA. 

Thank you for your consideration of this request. 

Sincerely, 

Thomas Cogan 

4619 176th Ave SE 

Bellevue, WA 98006 
Attachment 1 

Exemptions Requested 

Summary of Exemptions Requested 

The applicant seeks exemption form 14 CFR Part 21, Subpart H; 14 CFR 45.23; 14 CFR 

61.113(a)(b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2)(c); 14 CFTR 91.103; 14 CFR 91.109(a); 

14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a)(b); 14 CR 91.405(a); 

14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1) and (a)(2); and 14 CFR 91.417(a)(b). 

Specific Sections of 14 CFR From Which Applicant Seeks Exemption or 

Relief 

14 CFR Part 21, Subpart H- Airworthiness Certificates and 14 CFR § 91.203(a)(1) 

The FAA has stated that no exemption is needed from this section if a finding is made under 

Part 11 and Section 333 of the Reform Act that the UA selected provides an equivalent level of 

safety when compared to civil aircraft normally used for the same application. Given the 

small size of the UA and the operating procedures defined within the Operational 

Restrictions and Limitations section of the petition (Attachment 2), an equivalent level of 

safety is achieved and exemption is not required (see Grant of Exemption to Woods Hole 

Oceanographic Institution, Docket No. FAA-2015-2067). If however, the FAA determines that 

there are some characteristics of the chosen UA that fail to meet the requirements of the 

Reform Act, an exemption is requested. 

14 CFR § 45.23 (a)(b) and 91.9 (c)- Marking of the Aircraft 

Regulation 45.23 provides: (a) Each operator of an aircraft must display on that aircraft 

marks consisting of the Roman capita/letter "N" (denoting United States registration) followed 

by the registration number of the aircraft. Each suffix letter used in the marks displayed must 

also be a Roman capita/letter. (b) When marks include only the Roman capita/letter "N" and 

the registration number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also display on that 

aircraft near each entrance to the cabin, cockpit, or pilot station, 

in letters 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. 

Given the small size of the UA, the lettering stipulated will not be possible. In a previous 
The applicant seeks exemption to the extent that an FAA-approved Flight Manual is required. 

Following the Operations Manual provided by the manufacturer will provide an equivalent 

level of safety. Additionally, the PIC will conduct preflight actions, to include performing all 

required checklists, reviewing weather, flight requirements, battery charge, landing and 

takeoff distance, aircraft performance data, and contingency landing areas, before initiation of 

flight. 

14 CFR § 91.109- Flight Instruction 

Regulation 91.109 stipulates, in part, that (a) No person may operate a civil aircraft (except a 

manned free balloon) that is being used for flight instruction unless that aircraft has fully 

functioningdual controls. 

Given the size, speed and limited operational parameters of the UA, an equivalent level of safe 

training can be performed without dual controls. The FAA has issued several exemptions to 

this regulation: see Exemptions Nos. 11066, 11062,11067 A and 11065. 

14 CFR § 91.119- Minimum Safe Altitudes 

Regulation 91.119 stipulates, in part, that, Except when necessary for takeoff or landing, no 

person may operate an aircraft below the following altitudes: 

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without 

undue hazard to persons or property on the surface. (b) Over congested areas. Over any 

congested area of a city, town, or settlement, or over any open air assembly of persons, an 

altitude of 1,000 feet above the highest obstacle within a horizontal radius of2,000 feet of the 

aircraft. (c) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be operated 

closer than 500 feet to any person, vessel, vehicle, or structure. 

An exemption to 91.119(c) is required because UA operations will be conducted at altitudes 

no greater than 400 feet above the surface. The size, speed, weight and limited operational 

parameters of the UA allow for an equivalent level of safety. 

14 CFR § 91.121- Altimeter Settings 

Regulation 91.121 requires that (a) Each person operating an aircraft shall maintain the 

cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter 

that is set, when operating- (1) Below 18,000 feet MSL, to- (i) The current reported altimeter 

setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no 

station within the area prescribed in paragraph (a}{l}{i} of this section, the current reported 

altimeter setting of an appropriate available station; or (iii} In the case of an aircraft not 

equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting 

available before departure. 

Conventional aircraft are provided altitude data by a barometric altimeter that is most 
commonly set to a local barometric pressure and therefore reports altitude relative to MSL 

(Mean Sea Level). UA operations are restricted to altitudes no greater than 400 feet AGL 

(Above Ground Level). For this UA, a GPS derived altitude will be set to zero at the takeoff 

point providing real-time readout of the AGL to the PIC during flight operations, and will 

provide an equivalent level of safety. The FAA has issued several exemptions to this 

regulation: see Exemptions Nos. 11066, 11065, 11062 and 11063. 

14 CFR § 91.151- Fuel Requirements for Flight in VFR Conditions 

Regulation 91.151 stipulates that (a) No person may begin a flight in an airplane under VFR 

conditions unless (considering wind andforecastweatherconditions) there is enough fuel to fly 

to the first point of intended landing and, assuming normal cruising speed-(1) During the day, 

to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes. 

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

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

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

For the UA in this petition that has a maximum flight time of approximately 18 minutes, this 

regulation would effectively deny ability for the UA to operate. The applicant submits that an 

equivalent level of safety will be obtained by requiring that no UA flight will begin unless 

(considering wind and forecast conditions) there is enough battery charge to fly the planned 

route, return to the point of intended landing, and land with 25% of battery capacity in 

reserve. The FAA has issued several exemptions to this regulation: see Exemptions Nos. 

2689F, 5745,10673 and 10808. 

14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b)-

Maintenance Inspections 

Regulation 91.405(aJ 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) ofthis section, have discrepancies repaired as prescribed in Part43 

of this chapter ... " Regulation 91.407(a)(1) similarly makes reference to requirements in Part 

43. Regulation 91.409(a)(2) requires an annual inspection for the issuance of an airworthiness 

certificate. Regulation 91.417(aJ and (b) requires the owner or operator to keep records 

showing certain maintenance 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. 

Exemption from these regulations is needed because Part 43 and these sections apply 

only to aircraft with an airworthiness certificate. An equivalent level of safety will be 

obtained by requirement that the UA will have a flight and maintenance log. Maintenance 

and inspections will be accomplished in accordance with manufacturer 

recommendations. The FAA has issued several exemptions to this regulation: see 

Exemptions Nos.11066,11062, 11067Aand 11065. 
Attachment 2 

Operational Restrictions and Limitations 

The proposed operations outlined in this petition are for the use of a light-weight UA under controlled 

conditions. The operation ofthe UA will always be performed by a qualified Pilot-In-Command (PIC), 

as outlined below, to ensure that the UA will"not create a hazard to users of the national airspace 

system or the public". Given the small size of the UA and the restrictions outlined below, the applicant 

believes the operation outlined in this petition poses no hazard to the National Airspace System or 

national security. In addition, the operation of the UA under the limitations and conditions of this 

petition will serve to enhance safety, reduce costs, and reduce the environmental impacts relative to 

current methods of aerial photography and video production using manned fixed or rotor wing 

aircraft. 

The limitations and conditions to which the operator and acting UA PIC agree to be bound when 

conducting commercial operations under an FAA issued exemption include: 

1. Operations authorized by this grant of exemption will be limited to the DJI Inspire 1 Model 600 

with a weight of less than 55 lbs. 

2. The aircraft operated in accordance with this exemption will be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N-Number) markings 

in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable. 

3. All operations will be conducted in accordance with an Air Traffic Organization (ATO) -issued 

Certificate of Waiver or Authorization (COA). The exemption holder will apply for a new or 

amended COA if it intends to conduct operations that cannot be conducted under the terms of 

the COA 

4. This exemption and all documents needed to operate the UAS and conduct its operations in 

accordance with the conditions and limitations of a grant of exemption will be accessible 

during UAS operations and made available to the Administrator upon request. If a discrepancy 

exists between the conditions and limitations in the exemption and the procedures outlined in 

the operating documents, the conditions and limitations of the grant of exemption take 

precedence and must be followed. Otherwise, the operator will follow the procedures as 

outlined in its operating documents. The operator may update or revise its operating 

documents. The operator will be responsibility to track such revisions and present updated 

and revised documents to the Administrator or any law enforcement official upon request. The 

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

amendment to this grant of exemption. If the operator determines that any update or revision 

would affect the basis upon which the FAA granted this exemption, then the operator will 

petition for an amendment to its grant of exemption. The FAA's UAS Integration Office 

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(AFS-80) may be contacted if questions arise regarding updates or revisions to the operating 

documents. 

5. Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the 

Ground Control Station of the UAS any time the aircraft is operating. These documents will be 

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

6. The UA Pilot-in-Command (PIC) will hold either a current airline transport, commercial, 

private, recreational, or sport pilot certificate. The PIC will also hold a current FAA airman 

medical certificate or a valid U.S. driver's license issued by a state, the District of Columbia, 

Puerto Rico, a territory, a possession, or the Federal government. The PIC will also meet the 

flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated 

on his or her pilot certificate. 

7. The operator will not permit any PIC to operate unless the PIC demonstrates the ability to 

safely operate the UA in a manner consistent with how the UA will be operated under this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from persons, vessels, vehicles and structures. PIC qualification flight hours and 

currency will be logged in a manner consistent with 14 CFR § 61.51 (b). Flights for the 

purposes of training the operator's PICs and VOs (training, proficiency, and experiencebuilding) and determining the PIC's ability to safely operate the UA in a manner consistent 

with how the UA will be operated under this exemption are permitted under the terms of this 

exemption. However, training operations will 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 will operate the UA with 

appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 

8. UA will be operated at altitudes less than 400 feet AGL. 

9. UA will be flown at ground speeds no greater than 40 knots. 

10. A flight controller will be connected, by radio communication, to the UA during the entire 

flight, which will give the PIC flight information such as GPS Position, Altitude, Air speed, 

Battery Remaining, and other pertinent telemetry information. A secondary "slave" flight 

controller may be used by a camera operator for the sole purpose of controlling the UA 

camera, and at no time will be used to take control of the UA from the PIC. 

11. The UA will not operate within 5 nautical miles of an airport reference point (ARP) as denoted 

in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, 

the center of the airport symbol as denoted on the current FAA-published aeronautical chart, 

unless a letter of agreement with that airport's management is obtained or otherwise 

permitted by a COA issued to the exemption holder. The letter of agreement with the airport 

management will be made available to the Administrator or any law enforcement official upon 

request. 

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12. UA operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations 

will be conducted under visual meteorological conditions (VMC). Flights under special visual 

flight rules (SVFR) are not authorized. 

13. The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally from 

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

14. The UA will remain clear of and yield right of way to all manned aviation operations. 

15. The UA will 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 or U.S. driver's license. 

16. All operations will utilize a visual observer (VO). The UA will be operated within the visual line 

of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO and PIC will be able 

to communicate verbally at all times; electronic messaging or texting is not permitted during 

flight operations. The PIC will be designated before the flight and cannot transfer his or her 

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

duties required of the VO. 

17. The UAS may not be operated by the PIC from any moving vehicle except watercraft in open 

water. Takeoff and landing from a watercraft of suitable size with a deck capable of safely 

supporting flight operations is allowed as long as the marine vessel is not under power during 

the UA takeoff and landing phase of flight. 

18. All Flight operations will be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator will ensure that 

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

nonparticipating persons leave such protection and are within 500 feet of the UA, flight 

operations must cease immediately in a manner ensuring the safety of nonparticipating 

persons; and 

b. The owner/ controller of any vessels, vehicles or structures has granted permission for 

operating closer to those objects and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present an undue 

hazard. 

c. The PIC, VO, operator trainees or essential persons are not considered nonparticipating 

persons under this exemption. 

19. If the UAS loses communications or loses its GPS signal, the UA will return to a pre-determined 

location within the private or controlled-access property, or to the marine vessel from which it 

was launched. 

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20. The PIC will abort the flight in the event ofunpredicted obstacles or emergencies. 

21. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable COA will be reported to the FAA's UAS 

Integration Office (AFS-80) within 24 hours. Accidents will be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. 

22. The operator will be responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation. 

23. The operator will follow the UAS manufacturer's maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

24. Each UAS operated under this exemption will comply with all manufacturer safety bulletins. 

25. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the UAS 

(including both the aircraft and flight controller) is in a condition for safe flight. The pre-flight 

inspection will account for all potential discrepancies (e.g., inoperable components, items, or 

equipment). If the inspection reveals a condition that affects the safe operation of the UAS, the 

aircraft will be prohibited from operating until the necessary maintenance has been performed 

and the UAS is found to be in a condition for safe flight. 

26. The PIC will be prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the intended 

operation and to operate after that for at least five minutes or with the reserve power 

recommended by the manufacturer if greater. 

27. A Flight Operations and Maintenance Log will be maintained for each UA. Cumulative flight 

hours, maintenance activities, repairs, alterations and inspections will be lUEd 

28. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

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

prior to conducting further operations under this exemption. Functional test flights will only be 

conducted by a PIC with aVO and must remain at least 500 feet from other people. The functional 

test flight must be conducted in such a manner so as to not pose an undue hazard to persons and 

property. All maintenance or alterations as noted above will be entered into the Flight Operations 

and Maintenance Log. 

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Attachment 3 

Benefits to Public Interest 

The requested exemption would authorize the applicant to perform aerial photography and 

video production with a small UA for commercial purposes (e.g., support real estate survey 

and transactions, special events, and artistic photography), and would benefit the public interest as 

follows: 

1. In the past, methods to obtain high quality photographic and video products of similar 

nature have been conducted with manned fixed and rotor wing aircraft. The use of a small 

UA to obtain these products would provide a significant reduction in costs for those 

seeking these products, and make these products available for a segment of the population 

where the cost today is prohibitively expensive. 

2. The use of a small UA will reduce the noise, emissions, and air pollution generated when 

using more traditional manned aircraft flight operations for obtaining aerial photographs 

and video production. 

3. Operation of a small UA will substantially reduce the potential risk to life and property 

which is commonly associated with traditional manned aircraft flight operations in 

obtaining aerial photographs and video production. 

Approval of this exemption would thus provide economic benefits, reduce impact on the 

environment, and enhance safety, fulfilling the Secretary of Transportation's (the FAA 

Administrator's) responsibilities under Section 3 3 3 (c) of the Reform Act to "establish 

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

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Aircraft 

Remote 

Controller 

Attachment 4 

DJI Inspire 1 Model T600 Specifications* 

Model T600 

Weight (Battery Included) 2935 g 

Hovering Accuracy (GPS Mode) Vertical: 0.5 m 

Horizontal: 2.5 m 

Max Angular Velocity 

Max Tilt Angle 

Max Ascent Speed 

Max Descent Speed 

Max Speed 

Max Flight Altitude 

Max Wind Speed Resistance 

Max Flight Time 

Motor Model 

Propeller Model 

Indoor Hovering 

Operating Temperature Range 

Diagonal Distance 

Dimensions 

Name 

Operating Frequency 

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Pitch: 300° fs 

Yaw: 150° fs 

5m/s 

4m/s 

22 mfs (ATTI mode, no wind) 

4500m 

10 mfs 

Approximately 18 minutes 

DJI 3510 

DJI 1345 

Enabled by default 

559 to 581 mm 

438x451x301 mm 

C1 

922.7-927.7 MHz (Japan Only) 
Battery 

(Standard) 

Transmitting Distance 

(Outdoor And Unobstructed) 

EIRP 

Video Output Port 

Power Supply 

Charging 

Dual User Capability 

Mobile Device Holder 

Max Mobile Device Width 

Output Power 

Operating Temperature Range 

Storage Temperature Range 

Charging Temperature Range 

Battery 

Name 

Model 

Capacity 

Voltage 

Battery Type 

Energy 

Net Weight 

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5.725-5.825 GHz 

2.400-2.483 GHz 

2km 

10dBm@900m, 13dBm@5.8G, 

20dBm@2.4G 

USB, mini-HDMI 

Built-in battery 

DJI charger 

Host-and-Slave connection 

Tablet or Phone 

170mm 

9W 

-10° to 40° C 

Less than 3 months: -zoo to 45° C 

More than 3 months: 22° to 28° C 

6000 mAh LiPo 2S 

Intelligent Flight Battery 

TB47 

4500 mAh 

22.2 v 

LiPo 6S High voltage battery 

99.9Wh 

570 g 
Operating Temperature Range 

Storage Temperature Range 

Charging Temperature Range 

Max Charging Power 

*As of May 16, 2015 published on www.dji.com 

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-10° to 40° C 

Less than 3 months: -20° to 45° C 

More than 3 months: 22° C to 28° C 

180W