Leslie H. Cox 3512 Butler Drive Denton, TX 76210 September 23, 2015 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave. , SE Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103;14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b)
To whom it may concern: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, Leslie H
. Cox, hereby applies for an exemption from the listed Fed e ral Aviation Regulations to allow commercial operation of a small UAS, so long as such operations are conducted within and under the cond itions outlined herein or as may be established by the FAA as required by Section 333, for all operators of small Unmanned Aerial Systems (UAS) working for Leslie H. Cox. Commercial operation small UAS, as described herein, which are equipped with cameras and sensors, would operate in the following manner: 1. Aerial photography and/or video for public and/or private
. use including real estate , architecture, land surveying, engineering and other related professional acti v ities. 2. Aerial video and/or photography for public and/ or private use includ i ng television, public

events, and cinematography. 3. Aerial inspection/photog raphy of residential/commer cial structures under contract w ith the owners or local government authority. 4
. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or donation
. As described fully below, the requested exe mption would permit the operation of small UAS u nder controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) willprovide safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to "
....establish requi re ments for the safe operation of such aircraft systems in the national airspace system. n The name, phone, email and address of the applicant: Name : Leslie H. Cox Phone : 

### (972) 835-4594 Email: Leshcox@qmail.com Address : 3512 Butler Drive Denton, TX 76210 Regulations from which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113(a) 14 CFR 91.7 {a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119(c} 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) 

### & (b)
The small UAS's I will be using are multi-rotor craft weighing no more than 55 Ibs. including payload. Under normal conditions they operate at speeds of no more than 45 Mph or 39 Knots and have the ability hover and move along a vertical and horizontal plane simultaneously. They will operate in line of sight only and by the exempted persons only obeying all other local and federal laws. Given the small size of the small UAS and the controlled environme nt provided the proposed operations will adhere to the Reform Act's safety requirements

. The approval of this application presents no national security issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested exemption is in the public interest. Accordingly the applicant requests that the FAA grant the requested exemption with m i nimum delay
.

### AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The operation limitations proposed for an equivalent or higher level of safety because operat ion s will further enhance the safety of the perso ns and/ or property using con ve nti onal aircraft. These l i mitations and cond it ions to whi ch the ap plicant agrees to ad here to when cond uc t i ng commercial operations under the FAA issued exemption as set forth in the Flight Operat ions Manual (FOM} include: 

### 1. The small UAS will weigh less than 55 lbs. 2. Flights will be operated within line of sight of a pilot and/ or observer
. 3
. Max imum flight time for each o perational flight will be 30 minut es. Fl ights will 

### be te rminat ed at 25% battery power reserve or 30 minutes of flight time wh ichever occurs first. 4
. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AG L} and not more than 200 feet above an elevated platform from which f i lming is planned
. 5
. Mi nimum crew for each operation will consist of the small UAS Pi lot in Command ( PIC), the Visual Observer (VO} when needed and may include but not limited to a Camera Operator. 6. A briefing will be performed regarding the plannedsmall UAS operations pri or to each day's flight consi sting of all the days ' productio n activities. 7
. The PIC will obtain verbal/written consent of all persons i nvol ved with the plan ned operatio n and ensure that only consenting persons will be allowed with i n 100 feet of the flig ht operation, and the radius may be reduced to 30 feet based upon an equivalent leve l of safety determination, as required under the FOM
. With the adva nced permiss ion or di rection of th e FSDO, ope rations at closer range may be approved. 8. The PIC and VO will have been trained i n operation of small UAS and re ceive up-to-date information for the particu lar small UAS to be o perated and wi ll be abl e to show upon request th ei r compete nt ab il ity to operate the small UAS and/ or Camera. 9. The PIC and VO will be able to communicate by voice, radio, and/or text at all times. 10
. Written and/or verbal permission and perm its wi ll be obtained f ro m t errito rial, state, county or city jurisdictions, includ i ng law enforcement, fire or other approp ri ate g overnmenta l agencies when needed
.

11. Ifthe small UAS loses communications or loses GPS signal, the small UAS will have the capabi lit y to return t o a pre-determ i ned location with i n a designated locatio n and land autonomously.

12
. The small UAS will have the capability to abort a flight in case of unpredicted obs tacles, weather, or emergencies

. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C. F. R. §91.203 

### (a) (1) Subpart H, entitled Airworthiness Certificates , establishes the proced ura l requ irements fo r the issuance of airworthiness certificates as required by FAR §91.203 (a) (1)
. Given the size and limit ed operating area associated with the aircraft to be utilized by the Applicant, an exe m ption from Part 21 Sub part H meets the requirements of an equivalent level of safety unde r Part 11 and Sectio n 333 of t he Ref o rm Act. The F

ederal Aviation Act (49 U.S
. C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate , up o n consideratio n of t he size , weight, speed , operational capability, and prox imity to airports and popu lated are as of th e particula r small UAS
. In all cases, an ana lysis of these criteria demonstrates that the small UAS operated without an airworthiness certificate, in the restricted environment and under the condition s proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) op e rating with an airworthiness certificate wit hout the restrictions and cond itions pr o posed
. The small UAS to be operatedhereunder is less than 55 lbs. fully loaded, carrie s neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area . Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements. These safety enhancements provide a greater degree of safety to the public and p roperty owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly , application of these same criteria demonstrates that there is no credible threat to national security posed by the small UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load
. 14 C.F.R. § 45.23 (b), Marking of the Aircraft The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category ai rcraft 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. Even though the small UAS will have no airworthiness certificate, an exempt ion may be needed as the small UAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experi mental" can be placed. Given the size of the small UAS, two-inch lettering wi ll be impossib le. The word "Experimental" will be placed on the fuselage in compliance with §45.29 {f). The equivalent leve l of safety will be provided by having the small UAS marked on its fuselage as required by §45.29 {f) where the pilot, observer and others working with the small UAS will see the identification of the small UAS as "Experimental."
14 C.F.R. § 61.113(a): Private Pilot Privileges and Limitations: Pilot in Command. Pursuant to 14 CFR 61.113 (a), no person who holds a private pi lot certifi cate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire. Our small UAS do not carry any pilots or passengers nor property therefore I am seeking an exemption to 14 CFR 61.113(a). Although helpful , a pilot's license will not ensure remote control piloti ng skills. The risks attendant to the operation of small UAS is far less than the risk levels i nherent in the commercial activities outlined in 14 CFR 61. I feel the operation and limitations set forth in the FOM will equate to the safe operation of the small UAS
.
14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. The regulation requ ires that no person may operate a civi l aircraft un less it is in airworthy cond ition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety checklists prior to each flight an equivalent level of safety wi ll be provided
.14 C.F.R. § 91.9 (b) 

### (2}: Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2 ) provides: No pe rson may operate a U.S.-registered civi l ai rcraft
.. . (2) For which a n Airplane or Roto rcraft Flight Manual is not required by § 2 1.5 of this chapter, unless there is available in the airc raft a current approved a i rplane or Rot orcraft Flight Manual , approved manual material , markings, and placards, or any combination thereof. The small UAS, given its size and configuration has no ability or pl ace to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety w i ll be maintained by keeping the flight manual at the
.ground control point where the pilot flying the small UAS will have immediate access to it.
14 C.F.R. § 91.103: Preflight Action. This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for t he aircraft an exe mption will be needed
. The OPERATOR will take all action s including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.
14 C.F.R. §91.109 : Flight Instruction. Section 91.10 3 provid es that no person may operate a civil aircraft (exce pt a mann ed free balloon) that is being used for flight instruction unless th at ai rcraft has fully functioning dua l controls. Small UAS and remotely pil ot ed aircraft, by th e ir des ign do not have fully functional dual co ntrol s. Flight co ntrol i s accompli s hed through th e u se of a co ntrol box th at communi cates with th e aircraft via rad i o communi cations
. The FAA has approved exemption s for flight training without fully functional dual controls for a number of aircraft and for flight instru c tion in expe rim e ntal aircraft. T he equivalent lev el of s afety provid ed by th e fact that ne ith er a pilot nor passe ngers will be carried in the aircraft and by the s ize and speed of the aircraft.

14 C.F.R. §91.119: Minimum Safe Altitudes. Section 9 1.11 9 e stabli shes safe altitude s f or operat ion of civil aircraft. Sectio n 9 1.119 (d) allows helicopters to be operated at less than the minimum s prescribed, provided the person operating the h elicopter complies with any route or altit udes presc ribed for heli copters by the FAA. As this exemption is for a small UAS th at is a helicopter and the exemption requests authority t o operate at altitud es up to 400 AGL , or not more than 200 above an elevated platform from which filming is plann ed, an exemption may be needed to allow such operations. As se t forth he rein, the small UAS will never ope rate at higher than 400 AGL w ith the exception that in circumstan ces where the small UAS is use d to survey or ph otograph a stru cture who se h eight exceeds 400 f eet AGL, th e small UAS will not be operated mo re than 100' above the highest point on th e structure. It will however be operated i n a restricted area with security per i met e r , where building s and people will not be ex po sed to ope rat ions without thei r preobta ined co n sent. The equival e nt leve l of safety will be achieved gi ven th e s ize, wei g ht, spee d of the s mall UAS as we ll as th e locati on wh ere it i s operated. No flight w ill be take n without the permi ssi on of the propert y owner or local off i c ia l s . Because of th e advance n otice t o th e property own e r and pa rticipants in the filming activity, all affected indivi d ual s will be aware of th e plann ed flight ope ration s.Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 5Sibs
. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations of the small UAS will ensure separation between these small- UAS operations and the operations of conventional aircraft that must comply with Section 91.119.
14 C.F.R. §91.121 Altimeter Settings. This regulation requires each person operating an aircraft to maintain 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." As the small UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight
.
14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane 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 - (1} During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at feast 45 minutes." The battery powering the small UAS provides approximately 30 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, small UAS flights would be limited to approximately 10 minutes in length. Given the limitation s on the small UAS 's proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or twilight VFR condition s is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the small UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally, limiting small UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can be achi eve d by limiting flights to 30 minutes or 25% of battery power- whichever happens first. This restriction would be more than adequate to return the small UAS to its planned landing zone from anywhere in its limited operating area.
14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part : (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate
.... (b) No person may operate a civil aircraft unle ss the airworthin ess certificate required by paragraph (a) of thi s section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it i s legible to passengers or crew.The small UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to d isplay them on the small UAS
. An equivalent level of safety will be achieved by keeping these docume n ts at the ground control point where the pilot flying the small UAS will have immediate access to them; to the extent they are applicable to the small UAS
.


### 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & 

### (b): Maintenance Inspections. These regulations require that an aircraft operator or owner "shall have that ai rcraft 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
...," and others shall inspect or maintain the aircraft in compliance with Part 43
. Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not ap ply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because these small UASs are very limited in 

### siie and will carry a small payload and operate only in rest r icted areas for limited periods of time. If mechanical issues arise the small UAS can land immediately and will be operati ng fro m no higher than 400 f eet AGL. The operator will ensure that the small UAS is in working order prior to in itiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the ai rcraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the small UAS Manufacturer's Manual, as referenced in t he Aircraft Operations Manua l (AOM). As provided in the FOM, the operator will ensure that the small UAS is i n working order pri or to initiating flight and perform required maintenance needed.Small UAS Information Small UAS's to be used are as follows but not limited to providing they are within the scope of the exemption granted by the FAA: 1. DJI Phantom 3 Weight (Battery & Propellers Included) -2.8211bs. Hover Accuracy- Vertical: +/- .33ft (when Vision Positioning is active) or +/ - 1.64ft Horizontal:+/- 4.9 

### ft Max Yaw Angular Velocity -200°/s Max Tilt Angel - 35° Max Ascent Speed -16 ft/s Max Descent Speed
- 9 ft/s Max Aight Speed -36mph DJI Phantom 3 Battery o DJI 4480mAH UPo Battery DJI Phantom 3 Gimbal Controllable Range- Pitch -90 degrees to +30 degrees Stabilization
- 3-axis (pitch, roll, yaw) DJI Phantom 3 Camera o Operating Temperature Range -32°F -104°F o Sensor Size -1/2.3 in
. o Effective Pixels -14M o Resolution
- 4384x3288 o HD Video Recording • UHD: 4096x 2160p 2 4/25 , 3840x2160p 24/25/30 • FHD: 1920x1080p 2 4/2 5/30/48 /5 0/6 0 • HD: 1280x72 0p 24/25/30/48/50/60
o R eco rding Field of View - 110°/85 ° DJI Phantom 3 Transmitter o Operating Frequency -2.400GHz -2.483GHz o Communication Distance (unobstructed) -FCC Compliance: 2400 

### ft o Receiver Sensitivity { 1%PER) -lOldbm +/- 2dbm o Transmitter Power - FCC Compliance: 20dbm CE: 16d bm

Thank you for your time and consideration. Sincerely,

Les lie H. Cox