June 13th, 2015

U

.S

. Dept. ofTransportation , Docket Operations West Building Ground Floor, Room w12-140 1200 NewJerseyAvenue, SE. , Washington, DC 20590 VIA FEDERAL DOCUMENT MANAGEMENT SYSTEM Copter Studios 525 Poplar Way Windsor, CA 95492

Re: Exemption Request under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations Dear Sir or Madam: Pursuantto Section 333 ofthe FAA Modernization and Reform Act of 2012 (the "Reform Acf') and 14C.F.R. Part 11 , Copter Studios, seeks an exemption from FederalAviation Regulations ("EARs") detailed below for the following described UnmannedAerial System called in this application the ME System, which includes an Unmanned Aircraft (UA) and ground stationbased equipment and crew: THE UNMANNEDAIRCRAFT (UA) :

**~A** lightweight (20 lb gross weight with all on-board equipment) , manufactured by DJI , Inspire 1- t-600, Phantom 3, and S9000 that includes the following equipment in flight; 

## riD An on-board flight computer with GPS navigation and location ability that receives signals for flight controls from a ground-based transmitter/controller; 

### (i] An on-board camera capable of capturing imagery in the form offull color, high definition still photos and video ; 

## 00 An on-board telemetry system that delivers flight datafrom the on-board flight computer to the on-board radio transmitter including altitude AGL, horizontal and vertical speed, compass direction offlight and direction back to its launch site; 

## 00 A 2.4GHz on-board radio transmitter thattransmits live video from the on-board camera plus all the flight data from the telemetry system described above; THE GROUP STATION -BASED PART OFTHE SYSTEM: 

### (iJ A Pilot in Command (PIC) in operational control of a flight operation from beginning to end and who controls the UAwhile in the air; 

### (iJ A 2.4GHz radio transmitter/controller operated bythe PIC to control the UAwhile in flight; 

## liD A radio receiver receiving live video and flight datafrom the on-board camera and computer projects it all together onto a screen forthe PIC to view during flight; 

## 00 A Visual Observer (VO) is a person who provides a second pair of eyes to visually track the UAwhile in flight.The requested exemption would support an application for a commercial Certificate of Authorization to use the above described ME System to support video productionscommercials and motion pictures, real estate, and agricultural inspection never operating over persons not directly involved with the ME system. The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel , it operates at lower altitudes with no people on board and will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. With a small payload and maximum flight time of only 18 minutes, this is offers little or no risk to national security

. Low level oblique photos and video from several angles are far more effective than groundbased imageryfor displaying the characteristics of large, complex properties with several buildings and large trees. The alternative could be to charter a full-sized helicopter for this purpose, which has proven more costly than many potential clients are able to afford

. The benefits of reduced cost and improved qualityof presentation from the UAwill 

### be valuable to and benefrt many buyers and sellers of real property and marine property. Additionally, we request that we be allowed to use our system to benefit first responders nearby who might require assistance, including fire fighters, the police, the sheriff, et al. , while remaining subject to all limitations cited in this application as we do so. The ME System will be operated in the field with both a PIC and a VO in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" and with the following Restrictions: a) No flight will be made with a UAGross weight exceeding 55 pounds; b) All operations mustoccur in FAA Class G airspace at no more than 400ftAGL, at an airspeed of no more than 50 knots and no further than 3/4 NM from the PIC; c) All operations must utilize a visual observer (VO)

. The VO and PIC must be able to communicate byvoice at all times during a flight operation ; d) Operations will be restricted to flights over property with the permission of the property owner; e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR 

### § 61.51 (b), a minimum of 100flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least ten hours logged as a UApilot with a similar UA

### type; f) All required permits will be obtained from state and local government prior to operation; g) The ME System will not

### beoperated over densely populated areas; h) The ME System will not be operated at air shows; i) The ME System will not be operated over anyopen-air assembly of people; j)The ME System will not 

### be operated over heavily trafficked roads; k) The ME System will notbe operated within 5 NM of an airportor heliport; I) Operations will be restricted to dayonly and weather conditions equivalentto VFR; m) The PIC will briefthe VO and property owner about the operation and risk before the first flight at each new location; n) No flight may be made without a Pre-Flight Inspection by the PIC before each operation to ascertain that the UA is in a condition safe for flight (see Appendix A)

.The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 personnel Qualifications. Additionally, the PIC and VOwill perform maintenance on the system and will complete a course of maintenance instruction as partoftheir initial training. We submit that the combination ofthe UA's light weight, flight performance and ability, fully qualified flight crew and strictoperation underthe guidelines established in 8900.227, and under all ofthe Restrictions (a) through (n) listed above, the FAA can have full confidence that the operation will have an equivalent or greater level ofsafety than manned aircraft performing the same mission. The name and contact information ofthe applicant are: Copter Studios : Darin Huard Ph : 707-529-1530 Email : Copterstudios@yahoo

.com The regulations from which the exemption is requested are listed below. Beside each regulation number is the page ofthe attached Addendum upon which each may be found together with our proposed equivalent level ofsafetyfor each regulation :

- 14 CFR Part 21

... .............. ... ........ .. ...Addendum Page 1

- 14 CFR 91

.203
........ ...... .......... .........Addendum Page 1

- 14CFR 45.23, 45

.29
..... ........ .... .........Addendum Page 2

- 14 CFR 91.9
....... ... ..........................Addendum Page 2

- 14 CFR 61

.113, 61.133

.. ....... ...... ...... ..Addendum Page 2 -14 CFR 91

.109, 91.119, 91.121

..............Addendum Page 3

- 14 CFR 91

.151..

.... ............ .. ............ . Addendum Page 3

- 14CFR Subpart E (91.401
- 91.417)

......Addendum Page 3 -FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)

...Addendum 1 We are prepared to modifyor amend any part ofthis request to satisfy the need for an equivalent level ofsafety. Please contact us atanytime if you require additional information or clarification

. We lookforward to working with your office.
Si r 

### y,



# ~~ 

# lDh-d 'loHDarin H rd, Copter Studios Addendum containing Exemption Requests and Equivalent Level of SafetyAppendix A- Flight Manual's Appendix 

### 8 - Owner's Manual for UAADDENDUM EXEMPTION REQUESTSAND EQUIVALENT LEVELOF SAFETY Copter Studios requests an exemption from the following regulations aswell as any additional regulations that maytechnically apply to the operation ofthe ME System: 14 CFR Part 21, Subpart H: Airworthiness Certificates This part establishes the procedures forthe issuance of an airworthiness certificate. While the FAA continues to work to develop airworthinessstandards for Unmanned Aerial Systems, we request an experimental certificate be issued for the ME System under either or both of the following provisions: 21.191 Experimental certificates. Experimental certificates are issued forthe following purposes: (a) Research and development.Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and other operationsto show compliance with the airworthiness regulations including flights to show compliance for issuance oftype and supplemental type certificates, flights to substantiate major design 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 crew training , we would expectthat an experimental certificate would permit our commercial purpose as well. The aircraft will not carry persons or property, will not carryfuel, and will only fly under strict operational requirements. Combined with the UA's lightweight, being constructed primarily of carbon fiber and plastic, we propose thatthe UAwill 

### be at least as safe, if notsafer, than a conventionally certificated aircraft performing the same mission. If an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safety outlined in the previous paragraph. 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 or crew ."At a maximum gross weight of 6

.5 pounds, the UA is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meetthe intent of 91.203, we propose that documents deemed appropriate for this aircraft bythe FAA will 

### be co-located with the crew atthe ground control station and available for inspection upon request. In order to identifythe aircraft, we propose thatthe information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information plusthe word "EXPERIMENTAL" to satisfythe requirement of 14CFR 45

.23, which follows immediately after the proposed placard description below:Appendix A EXPERIMENTAL Manufacturer: DJI Innovations, Inc

. 950 E Baseline Ave. Ste. 210 Apache JunctionAZ 85119 Models: Inspire 1- t-600, Phantom 3, Phantom 2 vision plus, and S1000 14CFR 45

.23 Display of marks; general and 45.29 Size of marks

. These regulations provide that each aircraft must display "W and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must displaythe word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The UAdoes not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it bythe FAA. We propose to achieve an equivalent level ofsafety by including the word "EXPERIMENTAL

.. in the placard on the top ofthe aircraft, as shown above, where the PIC, VO and others in the vicinity of the aircraftwhile it is preparing for launch will be able to see the designation. Additionally, we feel thatthe permanent placard discussed in the previous paragraph will provide the aircraft's registration information atthe ground station. Finally, we will display atthe ground station a high contrast flag or bannerthat contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM ofthe ground station, the banner should 

### bevisible to anyone that observes the aircraft and chooses to investigate its point of origin. 14CFR 91.9 Civil aircraftflight manual, marking, and placard requirements. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume that the intent ofthis requirement isto ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation, the documentation would not be available to the crew during flight operations

. To obtain an equivalent level of safety and meetthe intent of 91

.9, we propose that a current, approved UA Flight Manual (AppendixA) must be available to the crew atthe ground station anytime the aircraft is in, or preparing for, flight. 14 CFR 61 .113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regulation provides that no person that holds a private pilot certificate may act as pilot in command of an aircraftfor compensation or hire. Subparagraph (b) allows a private pilotto act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight isonly incidental tothat business or employment; and (2) The aircraft does notcarry passengers or propertyfor compensation or hire. Our proposed operations require thatthe PIC must either 1. Hold a Sport Pilot Certificate issued bythe FAA, and have logged 25 hours of flight experience in this type of UA, or 2. Meetthe requirements of 8900.227 para 16(c)(2)(c) "Operations without a pilot certificate" in which the PIC is required to complete "FAA private pilot ground instruction" and pass "the FAA Private Pilot written examination." Since there are currently no means available for the pilot of aUAS to gain the experience in an equivalent category and class in order to applyfor a commercial pilot's license, we propose to generate an equivalent level of safety by requiring our pilots to complete, at a minimum, FAAcommercial pilot ground instruction and pass the FAA Commercial Pilot written examination in addition to completing the private pilot requirements. Since the aircraft cannot carry passengers or property, we feel we meetthe intentof 

### 61.113 Subparagraph (b) even though the intent of this application is to conduct a business. 

### 14 CFR 

### 91.109 Flight Instruction; Simulated instrumentflight and certain flight tests The regulation states that "No person mayoperate a civil aircraftthat is being used for flight instruction unless that aircraft hasfully functioning dual controls." The ME System ground-based control station consists of a small hand-held radio transmitter and while it does not offer a second setof "controls", both the student and instructor can, and will, operate the single setof controls simultaneously. With both student and instructor having "hands-on" the controls during flight, we feel that this technique meetsthe intent 

### 91.109 and provides an equivalent level of safety. 

### 14 CFR 

### 91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 

### 500feet to any person, vessel, vehicle, or structure. Since the aircraftwill be operating at a maximum of

### 400feetAGL, we cannot complywith this requirement. In order to provide an equivalent level of safety we will only fly over private property with a size of at least two acres with the permission ofthe owner of the property flown over. The aircraft will not be operated over congested areas or over anyopen air assembly of persons.The property owner will be briefed onthe expected route offlight and the associated risks to persons and property on the ground. The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface

. Therefore we maintain that dueto the small size ofthe UA, 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 1

### 00 NM ofthe aircraft

. The UAwill always fly below 

### 400 feetAGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the UAon-board computer to the display screen held bythe PIC, providing a constantly updated AGL readout. 

### 14 CFR 

### 91
. 151 Fuel requirements forflight 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. We feel the intention of this paragraph isto provide an energy reserve as a safety buffer for delaysto landing

.The UA is battery operated and the maximum duration offlight from a single battery charge is 18 minutes with a 20% reserve. Since the aircraft will neverfly more than 314 NM from the point of intended landing, a full battery charge atlaunch will ensure that we meetthe reserve energy requirement ofthis paragraph. We request an exemption tothe word "fuel" and ask for an equivalent interpretation with the word "energy". 14 CFR Subpart E (91.401
- 91.417)
- Maintenance, Preventive Maintenance, Alterations The regulation provides thatthe operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91

.409 require that the aircraft be "approved for return to service by a person authorized under 43

.7" after maintenance and inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." As provided in the Pre-Flight Checklist in AppendixA, the PIC will ensure that the aircraft is in an airworthy condition prior to everyflight and in addition conduct detailed inspections after everytwo hours offlight. Maintenance performed bythe PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on-board computer. All other maintenance will be performed bythe manufacturer or their designated repair facility

.The PIC will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level of safety. 8900

.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(1) Observer Medical. This policy provides that both the PIC and VO must have a valid FAA second-class medical certificate issued under part 67 in order to perform as a pilot or observer. The UA maximum gross weight is 6.5 pounds, it is constructed of carbon fiber and plastic and the PIC is noton board

. Both the PIC and the VO are required to be in VLOS. Given the unlikely eventthat both the PIC and VO become medically incapacitated while the aircraft is in flight, the UAwill return autonomously to the site of launching and land without crew intervention. Therefore, requiring the PIC and VO to meetthe same medical requirements as a commercial pilot carrying passengers in a large aircraft is an unnecessary burden. We propose thatthe minimum medical requirements forthe PIC and VO be vision corrected to 20120 and a valid, state issued driver's license. The 20/20 vision requirement will ensure that the PIC and VO can see and avoid air traffic; a licensed driver is medically qualified to operate a much largervehicle

.APPENDIXA- FLIGHT MANUAL FLIGHT RESTRICTIONS a) No flight will be made with a UAGrossweight exceeding 55 pounds; b) All operations mustoccur in FAA Class G airspace at no more than 400' AGL, at an airspeed of no more than 50 knots and no further than 3/4 NM from the PIC; c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate verbally at all times during a flight operation; d) Operations will be restricted toflights over property with the permission of the property owner; e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR 

### § 61

.51 (b) , a minimum of 100flight cycles and 25 hours oftotal time as a UA rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UAtype; f) All required permits will be obtained from state and local government prior to operation ; g) The ME System will not 

### be operated over densely populated areas; h) The ME System will not be operated at air shows; i) The ME System will not be operated over any open-air assembly of people; 

### j) The ME System will not be operated over heavilytrafficked roads ; k) The ME System will not be operated within 5 NM of an airport or heliport; I) Operations will be restricted to day only and weather conditions equivalent to VFR; m) The PIC will brief the VO and property owner aboutthe operation and risk before the first flight at each new location; n) No flight may be made without a successful Pre-Flight Inspection bythe PIC before each operation to ascertain that the UA is in a condition safe for flight. PREFLIGHT CHECKLIST 1. Remote controller, aircraft battery, and mobile device are fully charged. 2

. Propellers are mounted correctly and firmly

. 3

. Micro-SO card has been inserted if necessary
. 4. Gimbal is functioning as normal. 5. Motors can start and are functioning as normal. 6. DJI Pilot app connected to the aircraft

. TO REGAIN CONTROLAFTER LOST RADIO CONTACT If radio contact is lost and not restored within 3 seconds, an automatic Return to Home feature is activated and will bring the UAV back to the PIC

.