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November	20,	2015	

U.	S.	Department	of	Transportation	

Docket	Operations	West	Building	Ground	Floor,	Room	W12-140	1200	

New	Jersey	Ave,	SE	

Washington,	DC	20590	

Subject:	 Exemption	Request	Section	333	of	the	FAA	Reform	Act	of	the	Federal	Aviation	

Regulations	

Dear	Sir	or	Madam,	

I,	Gregory	A.	Cook, owner	of	CooksArt,	am	writing	pursuant	to	the	FAA	Modernization	and	Reform	Act	of	2012	

and	the	procedures	contained	within	14	C.F.R.	11,	to	request	that	CooksArt, a	photography	business	

specializing	in		Real	Estate,	Sports,	and	Landscape	photography,	be	exempted	from	the	below	so	that	we	may	

operate	a	small	ultra-lightweight	unmanned	aircraft	system.	

As	described	here	I,	Gregory	A.	Cook,	am	chief	photographer	/	videographer	at	CooksArt which	has	acquired	a	

DJI	Inspire	1	Pro	small	ultra-lightweight unmanned	aerial system	(sUAS)	with	a	4K	Video	Camera	with	16	

megapixel	still	capability, with	intent	to	operate	it	for	commercial	aerial	photography	/	videography	following	

exemption	and	approval	by	the	FAA.	

Exemption	request	would	permit	operation	of	ultra-light	weight,	unmanned	(piloted	by	remote	control)	and	

comparatively	inexpensive	sUAS in	tightly	controlled	and	limited	airspace	photographing	or	videographing	

within	property	boundaries	for	individual	property	owners	with	their	permission	as	well.	

I,	Gregory	A.	Cook,	owner	of	CooksArt, will	detail	in	this	petition	the	specific	regulations	for	which	we	seek	

relief,	offering	alternate	and	equivalent	ways	of	providing	a	level	of	safety	at	least	equal	to	the	existing	rules.	

This	petition	focuses	on	public	safety	and	public	benefit.	

I.	About	the	Operator	of	the	sUAS:

Gregory	A.	Cook	is	a	licensed	helicopter	and	single	engine	land	pilot	with	over	1000	hours	pilot	in	

command	of	Cessna	aircraft	and	400	hours	in	Robinson	helicopters.	He	is	a	former	owner	of	a	Cessna	

152,	172	and	182	single	engine	aircraft	and	a	Robinson	R-44	four-person helicopter.	His	flying	

experience	in	aircraft	and	helicopters	has	given	him	extensive	knowledge	of	FAA	rules	and	regulations	

along	with	a	thorough	understanding	of	aviation	weather	and	national	airspace	rules	and	regulations.

In	addition,	he	has	gained	knowledge	of	the	sUAS operations	by	flying	them	as	a	hobbyist.

		Contact	Information:	

Gregory	A.	Cook

DBA:	CooksArt

58-145	Napoonala	Place

Haleiwa,	Hawaii,	96712

Phone:	310-261-3234 																																								Email:	Captaincook@arthlink.net
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II.	The	specific	sections	of	title	14	of	the	code	of	federal	regulations	from	which	

CooksArt	requests	exemption	are:	

14	C.F.R.	Part	21	subpart	H;		14	C.F.R.	45.23(b);		14	C.F.R.	61.113(a)&(b);		14	C.F.R.	91.7(a);	91.9(b)	(2);	

91.103(b);	91.109;	119.121; 91.151(a);	91.203(a)&(b);	91.405(a);	91.407(a)	(1);	91.409(a)	(2);	91.417(a)&(b)	

III.	The	extent	of	relief	CooksArt	seeks	and	the	reason	he	seeks	such	relief:	

I,	Gregory	A.	Cook,	submit	this	application	in	accordance	with	the	Reform	Act,	112	P.L.	95	§§	331334,	

seeking	relief	from	any	currently	applicable	FARs	operating	to	prevent	CooksArt contemplated

commercial	use	of	an	sUAS	for	photography and	videography	use	within	the	national	airspace	system.	

The	Reform	Act	in	Section	332	provides	for	such	integration	of	civil	unmanned	aircraft systems	into	our	

national	airspace	system	as	it	is	in	the	public's	interest	to	do	so.	Our	ultra	lightweight	sUAS	meets the

definition	of	"small	unmanned	aircraft"	as	defined	in	Section	331	and	therefore	the integration	of	my	

ultra	lightweight	sUAS	is	expressly	contemplated	by	the	Reform	Act.		We	would	like	to	operate	our	

ultra	lightweight	sUAS	prior	to	the	time	period	by	which	the	Reform	Act	requires	the	FAA	to	

promulgate	rules	governing	such	craft.		Allowing	such	will provide	direct	experience	and	valuable	

information	for	formal	regulation	that	can	be	administered	uniformly	to	other	sUAS-related	activities	

for	aerial	video	and	photography.	

The	Reform	Act	guides	the	Secretary	in	determining	the	types	of	sUAS's	that	may	operate	safely	in	our	

national	airspace	system.		

Considerations	include:

The	weight,	size,	speed	and	overall	capabilities	of	the	sUAS's;	

Whether	the	sUAS	will	be	operated	near	airports	or heavily	populated	areas;	and,	whether	the	sUAS	

will	be	operated	by	line	of	sight.		112	P.L.	95	§	333	(a).		

Each	of	these	items	reflects	in	favor	of	an	exemption	for	CooksArt.		

Our	sUAS	utilizes	four	(4)	counter-rotating	propellers	for	balance,	control	and	stability.		Our	sUAS	is	

equipped	with	GPS	and	auto	return,	fail-safe	safety	technology,	and weighs	approximately	seven	(7)	

pounds	(far	below	the	maximum	55	pounds	limit);	including	camera	with	gimbal.	

Safety,	is	considered	by	CooksArt to	be	the	most	important	requirement	for	each	and	every	flight.

Our	small-unmanned	aircraft	is	designed	to	hover	in	place	via	GPS	and	operate	in	less	than	a	24	knots	

of	wind.		For	safety,	stability	and	fear	of	financial	loss,	we	will	not	fly	in	winds	exceeding	18 knots.		

Built-in	safety	systems	include	a	GPS	mode	that	allows	my	sUAS	to	hover	in	place	when	radio	controls	

are	released.		With	three	modes	to	choose	from,	we	utilize	the	GPS	mode	for	aerial	

videography/photography.		This	is	the	safest,	most	reliable	and	stable	mode	to	prevent	accident	and	

hazard.		When	pilot	communication is	lost,	the	sUAS	is	designed	to	go	into	a	Fail-Safe	mode	and	slowly	

return-to-home;	i.e.,	within	3	meters	of	the	point	of	take	off.			In	accordance	with	FAA	regulations,	we	

do	not	operate	our	sUAS	near	airports,	within	temporary	flight	restricted	areas,	near	hospitals	or	

sporting	event	areas,	near	special	security	areas,	and	do	not	operate	near	areas	where	general	public	is	

anywhere	within	150	feet.		With	an	observer	always	present,	we	are	constantly	on	alert	for	both	

people	on	the	ground	and	manned	aircraft	in	the	air,	and	prepared	to	land/abort	immediately	to	the	

nearest	and	safest	ground	point	should	a	manned	aircraft	approach	my	location	or	I	suspect	manned	

aircraft	may	approach	near	my	location.	
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We	do	not	believe	in	taking	any	risk	that	may	cause	any	harm	or	crash	that	could	create	a	hazard	to	the	

public,	to	property	or to	manned	aircraft,	and	have	no	desire	to	lose	an	investment.		We	have	recorded	

numerous	practice	flights	in	remote	areas	as	a	hobbyist	simulating	flights	for	future	commercial	use	to

gain	familiarization	with	the	characteristics	of	this	specific	sUAS's	performance	under	different	

temperature	and	weather	conditions.		We	also	practice	computerized	simulated	flights	to	maintain	

adequate	skills	and	response	reflex	time.	

CooksArt chief	pilot	will	be	me,	Gregory	A.	Cook,	owner	of	CooksArt.	I	am	extremely	cautious	when	

operating	our	sUAS	/	ultra-lightweight	unmanned	aircraft.	My	Inspire	1	Pro sUAS,	used	in	hobby	flight,	

has	a	demonstrated	safety	record	and	does	not	pose	any	threat	to	the	general	public.	In	addition,	as	an	

owner/operator	of	three	aircraft	and	a	helicopter,	I	have	extensive experience	in	safe	aircraft	and	

helicopter	safety,	operations,	aviation	weather,	and	National	Airspace	rules	and	regulations.

IV.	How	CooksArt request	will	benefit	the	public	as	a	whole:	

The	operation	of	small	sUAS,	weighting	less	than	55	lbs.,	conducted	in	the	strict	conditions	outlined	

above,	will	provide	an	equivalent	level	of	safety	supporting	the	grant	of	the	exemptions	requested	

herein,	including	exempting	the	applicant	from	the	requirements	of	Part	21	and	allowing	commercial	

operations.	These	lightweight	aircraft	operate	at	slow	speeds,	close	to	the	ground,	and	in	a	sterile	

environment	and,	as	a	result,	are	far	safer	than	conventional	operations	conducted	with	traditional	

aircraft,	which pose	a	safety	risk.		There	are	no	personnel	on	board	the	sUASs	and	therefore	the	

Likelihood	of	death	or	serious	bodily	injury	is	significantly	diminished. Flights	will	occur	over	private	or

Controlled	access	property	with	the	property	owner's	prior	consent	and	knowledge.	Filming	will	be	of	

People	who	have	also	consented	to	being	filmed	or	otherwise	have	agreed	to	be	in	the	area	where

filming	will	take	place.	CooksArt will	provide	an	equivalent	or	better	level	of	safety	as	that	achieved	

under	the	current	FAR's.	

Our	ultra	lightweight	sUAS	is	battery	powered	and	creates	no	emissions	that	can	harm	the	

environment.	The	consequence	of	our	ultra	lightweight	sUAS	crashing	is	far	less	than	a	full	size	

helicopter or	fixed	wing	aircraft;	which	are	heavy,	contain	a	pilot,	many	gallons	of	combustible	fuel	and	

can	cause	catastrophic	devastation	to	the	public.		The	Smart	Battery	employed	in	Inspiration	1	sUAS

provides	immediate	visual	awareness	and	percent	battery	charge	remaining	as	well	as	similar	

information	during	flight	through	the	Ground Control	Station.	

Granting	CooksArt exemption	request	furthers	the	public	interest	through	visual	awareness	of	the	

geographical	benefits.	In	furtherance	of	the	public's interest͕we	would	also	make	our	services	available	

on	a	volunteer/no-cost	basis	to	local	Not-for-Profit	/	Search	and	Rescue	/	Fire	Fighting	organizations.	

V.	Reasons	why	CooksArt exemption	will	not	adversely	affect	safety	or	how	the	exemption	

will	provide	a	level	of	safety	at	least	equal	to	existing	rule:	

CooksArt proposes	that	the	exemption	requested	herein	apply	to	civil	aircraft	that	have	the	

characteristics	and	that	operate	with	the	limitations	listed	herein.		These	limitations	provide	for	at	least	

an	equivalent	or	even	higher	level	of	safety	to	operations	under	the	current	regulatory	structure	

because	the	proposed	operations	represent	a	safety	enhancement	to	the	already	safe	aerial	

photography	and	cinematography	filming	operations	conducted	with	conventional aircraft.	
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These	limitations	and	conditions	to	which	CooksArt agrees	to	be	bound	when	conducting	

commercial	operations	under	an	FAA	issued	exemption	include:	

1.	The	sUAS	will	weigh	less	than	55	lbs.	

2.	Flights	will	be	operated	within	line	of	sight	of	a	pilot	and/or	observer.	

3. Maximum	total	flight	time	for	each	operational	flight	will	be	30	minutes	or	less. Flights	will	be

terminated	at	25%	battery	power	reserve	should	that	occur	prior	to	the	30	minute	limit.	

4.	Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet		AGL	or,	not	more	than	200	feet	above	an	

elevated	platform	for	which	filming	is	planned.

5.	Minimum	crew	for	each	operation	will	consist	of	CooksArt	sUAS	pilot,	Gregory	A.	Cook,	and	the	Visual	

Observer.	

6.	sUAS	Pilot	will	also	meet	the	flight	review	requirements	specified	in	14C.F.R61.56	in an	aircraft in which	the	

Pilot	is	rated	on	his	or	her	pilot	certificate.

7.	The	sUAS	will	only	operate	within	a	confined	sterile	closed-set	area	with	a	set	safety	perimeter,	the	

boundaries	of	which	will	be	determined	by	production	personnel	based	on	the	site-specific	filming	activities	

and	speed	of	the	sUAS	required	for	the	operation,	and	coordinated	with	the	jurisdictional	FAA	FSDO	and	local	

government	officials	as	applicable.

8. A	briefing	will	be	conducted	in	regards	to	the	planned	sUAS	operations prior	to	each	day's	production

activities.		It	will	be	mandatory	that	all	personnel	who	will	be	performing	duties	within	the	boundaries	of	the	

safety	perimeter	be	present	for	this	briefing.

9.	The	sUAS	Pilot	will	ensure	this	safety	perimeter	that	only	consenting	production	personnel	will	be	allowed	

within	100	feet	of	the	sUAS	operation	by	not	permitting	anyone	who	had	not	been	briefed	or	whom	is	not	

involved	in	production	to	be	in	the	closed-set	area.	

10.	Written	and/or	oral	permission	from	the	relevant	property	holders	will	be	obtained.	

11.	If	applicable,	all	required	permissions	and	permits	will	be	obtained	from	territorial,	state,	county	or	

city jurisdictions͕including local	law	enforcements,	fire,	or	other	appropriate	governmental	agencies.

12.	The	sUAS will have the capability to abort flight in case of unpredicted obstacles or emergencies.	

13.	PREFLIGHT	CHECKLIST	

a.	Remote	controller,	aircraft	battery,	and	mobile	device	are	fully	charged.	

b.	Propellers	are	mounted	correctly	and	firmly.	

c.	Micro-SD	card	has	been	inserted	if	necessary.	

d.	Gimbal	is	functioning	as	normal.

e.	Motors	can	start	and	are	functioning	as normal.	

f.	DJI	Pilot	app	connected	to	the	aircraft.	
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14.	TO	REGAIN	CONTROL	AFTER	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	sUAS	back	to	the	Pilot.	

15.	C.F.R.	Overviews	and	Requested	Exemptions:

14	C.F.R.	Part	21,	Subpart	H:	Airworthiness	Certificates	14	C.F.R.	§91.203	(a)	(1)	

C.F.R.	Overview:

Subpart	H,	entitled	Airworthiness	Certificates,	establishes	the	procedural	requirements	for	the	issuance	of	

airworthiness	certificates	as	required	by	FAR	§91.203	(a)	(1).	

Exemption	Request:

Given	the	size	and	limited	operating	area	associated	with	the	aircraft	to	be	utilized	by	the	Applicant,	an	

exemption	from	Part	21	Subpart	H	meets	the	requirements	of an	equivalent	level	of	safety	under	Part	11	

and	Section	333	of	the	Reform	Act.	The	Federal	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,	upon	consideration	of	the	size,	weight,	speed,	operational	capability,	and	proximity	to	airports	

and	populated	areas	of	the	particular	sUAS.	In	all	cases,	an	analysis	of	these	criteria	demonstrates	that	the	

sUAS	operated	without	an	airworthiness	certificate,	in	the	restricted	environment	and	under	the	

conditions	proposed	will	be	at	least	as	safe,	or	safer,	than	a	conventional	aircraft	(fixed	wing	or	rotorcraft)	

operating	with	an	airworthiness	certificate	without	the	restrictions	and	conditions	proposed.	The	sUAS	to	

be	operated	hereunder	is	less	than	55	lbs.	fully	loaded,	carries	neither	a	pilot	nor	passenger,	carries	no	

explosive	materials	or	flammable	liquid	fuels,	and	operates	exclusively	within	a	secured	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,	to	provide	

security	for	the	area	of	operation	as	is	now	done	with	conventional	filming.	The	FAA	will	have	advance	

notice	of	all	operations.	These	safety	enhancements,	which	already	apply	to	civil	aircraft	operated	in	

connection	with	motion	picture	and	television	production,	provide	a	greater	degree	of	safety	to	the	public	

and	property	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	sUAS,	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:	

C.F.R.	Overview:

When	marks	include	only	the	Roman	capital	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.	Even	though	the	sUAS	will	have	no	airworthiness	

certificate.	
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Exemption	Request:

An	exemption	may	be	needed	as	the	sUAS	will	have	no	entrance	to	the	cabin,	cockpit	or	pilot	station on

which the word "Experimental" can be placed. Given the size of the sUAS͕two-inch	lettering	will	be	

impossible.	The	word	"Experimental"	will be	placed	on	the	fuselage	in	compliance	with	§45.29 (f).	The	

equivalent	level	of	safety	will	be	provided	by	having	the	sUAS	marked	on	its	fuselage	as	required	by	§45.29	

(f)	where	the	pilot,	observer	and	others	working	with	the	sUAS	will	see	the	identification	of	the	sUAS	

"Experimental." The FAA	has	issued	the	following	exemptions	to	this	regulation	to	Exemptions	Nos.	10700,	

8738,	10167	and	10167A.	

14	C.F.R.	§	61.113	(a)	& (b):	Private	Pilot	Privileges	and	Limitations:	Pilot	in	Command.	

C.F.R.	Overview:

Sections	61.113	(a)	&	(b)	limit	private	pilots	to	non-commercial	operations.	

Exemption	Request:

Because	the	sUAS	will	not	carry	a	pilot	or	passengers,	the	proposed	operations	can	achieve	the	equivalent	

level	of	safety	of	current	operations	by	requiring	the	PIC	operating	the	aircraft	to	have	no	less	than	40	

hours	of	flight	time	with	the	sUAS.	Unlike	a	conventional	aircraft	that	carries	the	pilot	and	passengers,	the	

sUAS	is remotely	controlled	with	no	living	thing	on	board.	The	area	of	operation	is	controlled	and	

restricted,	and	all	flights	are	planned	and	coordinated	in	advance.	

14	C.F.R.	§91.7(a):	Civil	aircraft	airworthiness.	

C.F.R.	Overview:

The	regulation	requires	that	no	person	may	operate	a	civil	aircraft	unless	it	is	in	airworthy	condition.	

Exemption	Request:

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,	as	set	forth	in	Sections	J,	L	and	Q,	an	

equivalent level	of	safety	will	be	provided.	

14	C.F.R.	§	91.9	(b)	(2):	Civil	Aircraft	Flight	Manual	in	the	Aircraft.	

C.F.R.	Overview:

Section	91.9	(b)	(2)	provides:	No	person	may	operate	a	U.S.-registered	civil	aircraft	...	(2)	For	which	an	

Airplane	or	Rotorcraft	Flight	Manual	is	not	required	by	§21.5	of	this	chapter,	unless	there	is	available	in	the	

aircraft	a	current	approved	airplane	or	Rotorcraft	Flight	Manual,	approved	manual	material,	markings,	and	

placards,	or	any	combination	thereof.	

Exemption	Request:

The	sUAS,	given	its	size	and	configuration	has	no	ability	or	place	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	will	be	maintained	by	keeping	the	flight	manual	at	

the	ground	control	point	where	the	pilot	flying	the	sUAS	will	have	immediate	access	to	it.	The	FAA	has	

issued	the	following	exemptions	to	this	regulation:	Exemption	Nos.	8607,	8737,	8738,	9299,	9299A,	9565,	

9565B,	10167,	10167A,	10602,	32827,	and	10700.
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14	C.F.R.	§	91.103:	Preflight	action	

C.F.R.	Overview:

This	regulation	requires	each	pilot	in	command	to	take	certain	actions	before	flight	to	insure	the	safety	of	

flight.	

Exemption	Request:

As	FAA	approved	rotorcraft	flight	manuals	will	not	be	provided	for	the	aircraft	an	exemption	will	be	

needed.	The	PIC	will	take	all	actions	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

C.F.R.	Overview:

Section	91.103	provides	that	no	person	may	operate	a	civil	aircraft	(except	a	manned	free	balloon)	that	is	

being	used	for	flight	instruction	unless	that	aircraft	has	fully	functioning	dual	controls.	

Exemption	Request:

sUASs	and	remotely	piloted	aircraft,	by	their	design	do	not	have	fully	functional	dual	controls.	Flight	

control	is	accomplished	through	the	use	of	a	control	box	that	communicates	with	the	aircraft	via	radio	

communications.	The	FAA	has	approved	exemptions	for	flight	training	without	fully	functional	dual	

controls	for	a	number	of	aircraft	and	for	flight	instruction	in	experimental	aircraft.	See	Exemption	

Nos.5778K	&	9862A.	The	equivalent	level	of	safety	provided	by	the	fact	that	neither	a	pilot	nor	passengers	

will	be	carried	in	the	aircraft	and	by	the	size	and	speed	of	the	aircraft.	

14	C.F.R.	§91.119:	Minimum	safe	altitudes	

C.F.R.	Overview:

Section	91.119	establishes	safe	altitudes	for	operation	of	civil	aircraft.	Section	91.119	(d)	allows	helicopters	

to	be	operated	at	less	than	the	minimums	prescribed,	provided	the	person	operating	the	helicopter	

complies	with	any	route	or	altitudes	prescribed	for	helicopters	by	the	FAA.	

Exemption	Request:

As	this	exemption	is	for	a	sUAS	that	is	a	helicopter	and	the	exemption	requests	authority	to	operate	at	

altitudes	up	to	400	AGL,	or	not	more	than	200	above	an	elevated	platform	from	which	filming	is	planned,	

an	exemption	may	be	needed	to	allow	such	operations.	As	set	forth	herein,	the	sUAS	will	never	operate	at	

higher	than	400	AGL	with	the	exception	that	in	circumstances	where	the	sUAS	is	used	to	survey	or	

photograph	a	structure	whose	height	exceeds	400	feet	AGL,	the	sUAS	will	not	be	operated	more	than	100'

above	the	highest	point	on	the	structure.	It	will	however	be	operated	in	a	restricted	area	with	security	

perimeter,	where	buildings	and	people	will	not	be	exposed	to	operations	without	their	pre-obtained	

consent.	The	equivalent	level	of	safety	will	be	achieved	given	the	size,	weight,	speed	of	the	sUAS	as	well	as	

the	location	where	it	is	operated.	No	flight	will	be	taken	without	the	permission	of	the	property	owner	or	

local	officials.	Because	of	the	advance	notice	to	the	property	owner	and	participants	in	the	filming	activity,	

all	affected	individuals	will	be	aware	of	the	planned	flight	operations.	Compared	to	flight	operations	with	

aircraft	or	rotorcraft	weighting	far	more	than	the	maximum	55lbs.	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	the	movie	industry.	In	addition,	the	low-altitude	
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operations	of	the	sUAS	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	

C.F.R.	Overview:

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."

Exemption:

As the	sUAS may	not	have	a	barometric	altimeter͕but	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	

C.F.R.	Overview:

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	

minutes͖or (2) At	night͕to fly	after	that	for	at	least	45	minutes."

Exemption	Request:

The	battery	powering	the	sUAS	provides	approximately	30	minutes	of	powered	flight.	To	meet	the	30	

minute	reserve	requirement	in	14	CFR	§91.151,	sUAS	flights	would	be	limited	to	approximately	10	minutes	

in	length.	Given	the	limitations	on	the sUAS'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	

conditions	is	reasonable.	Applicant	believes	that	an	exemption	from	14	CFR	§91.151(a)	falls	within	the	

scope	of	prior	exemptions.	See	Exemption	10673	(allowing	Lockheed	Martin	Corporation	to	operate	

without	compliance	with	FAR	91.151	(a)).	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	sUAS	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	achieved	by	limiting	flights	to	30	minutes	or	25%	of	battery	power—

whichever	happens	first.	This	restriction	would	be	more	than	adequate	to	return	the	sUAS	to	its	planned	

landing	zone	from	anywhere	in	its	limited	operating	area.	Similar	exemptions	have	been	granted	to	other	

operations,	including	Exemptions	2689F,	5745,	10673,	and	10808.	

14	C.F.R.	§91.203	(a)	and	(b):	Carrying	Civil	Aircraft	Certification	and	Registration

C.F.R.	Overview:

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	unless	the	airworthiness	certificate	required	by	paragraph	(a)	of	
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this	section	or	a	special	flight	authorization	issued	under	§91.715	is	displayed	at	the	cabin	or	cockpit	

entrance	so	that	it	is	legible	to	passengers	or	crew.	

Exemption	Request:

The	sUAS	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	display	them	on	the	sUAS.	An	

equivalent	level	of	safety	will	be	achieved	by	keeping	these	documents	at	the	ground	control	point	where	

the	pilot	flying	the	sUAS	will	have	immediate	access	to	them,	to	the	extent	they	are	applicable	to	the	sUAS.	

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	C.F.R.	§91.405	(a);	407	(a)	(1);	409	(a)	(2);	417(a)	&	(b):	Maintenance	Inspections	

C.F.R.	Overview:

These	regulations	require	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 section͕have	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	apply	to	the	applicant.	

Maintenance	will	be	accomplished	by	the	operator	pursuant	to	the	flight	manual	and	operating	handbook.	

Exemption	Request:

An	equivalent	level	of	safety	will	be	achieved	because	these	small	UASs	are	very	limited	in	size	and	will	

carry	a	small	payload	and	operate	only	in	restricted	areas	for	limited	periods	of	time.	If	mechanical	issues	

arise	the	sUAS	can	land	immediately	and	will	be	operating	from	no	higher	than	400	feet	AGL.	The	operator	

will	ensure	that	the	sUAS	is	in	working	order	prior	to	initiating	flight,	perform	required	maintenance,	and	

keep	a	log	of	any	maintenance	performed.	Moreover,	the	operator	is	the	person	most	familiar	with	the	

aircraft	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	sUAS	Manufacturer's	Manual,	as	referenced	in	the	Aircraft	Operations

Manual.	As	provided	in	the	Operations	Manual,	the	operator	will	ensure	that	the	sUAS	is	in	working	order	

prior	to	initiating	flight	and	perform	required	maintenance	needed.	

Privacy	

All	flights	will	occur	over	private	or	controlled	access	property	with	the	property	owner's	prior	consent	and	

knowledge.	

Summary	

CooksArt is	seeking	exemption	from	the	following	rules:		14	C.F.R.	Part	21	subpart H;	14	C.F.R.	45.23(b);		14	

C.F.R.	61.113(a)&(b);		14	C.F.R.	91.7(a);	91.9(b)	(2);	91.103(b); 91.109;	119.121;	91.151(a);	91.203(a)&(b);	

91.405(a);	91.407(a)	(1);	91.409(a)	(2);	91.417(a)&(b)	

Approval	of	the	above	exemptions	allowing	commercial	operations	of	small	UASs	in	the	service	of	aerial	

photography	will	greatly	enhance	safety	by	reducing	the	overall	risk	associated	with	traditional	aircraft.	

Traditional	aerial	photography	requires	large	aircraft	weighing	thousands	of	pounds	and	carrying	hundreds	of

pounds of	fuel	presenting	a	significant	risk	to	life	and	property.	With	CooksArt use	of	small	UASs	weighing	less	

than	55	lbs,	powered	by	batteries	and	operating	at	or	below	400	AGL	they	virtually	eliminate	all	of	the	risk	
10

associated	with	traditional	aerial	photography.	The	UASs	will	carry	no	people	thereby	eliminating	the	exposure	

to	the	risks	associated	with	flying	while	accomplishing	the	same	task	in	a	much	safer	manner.	

Granting	CooksArt the	above	exemptions	will	allow	for	the	expansion	of	UAS	systems into	the	future,	in	a	

professional,	safety	conscious	culture	steep	in	the	tradition	of	Aviation.	

CooksArt respectfully	requests	that	the	FAA	grant	its	exception	without	delay.	The	FAA	has	the	authority	to	

issue	the	exemption	sought	by	CooksArt pursuant	to	the	Federal	Aviation	Act,	85	P.L.	726	(1958),	as	amended	

(the	"Act").	

Sincerely,	

_____________________________

Gregory	A.	Cook

CooksArt

58-145	Napoonala	Place

Haleiwa,	Hawaii	96712