July 27th, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., 

Washington, DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act'') 

and 14 C.F.R. Part 11, Cowles Enterprises, LLC, an operator of Unmanned Aircraft Systems 

("UAS'') for aerial data acquisition including but not limited to the following industries: aerial 

photography, aerial videography, motion picture and television, real estate, short range 

inspection, mapping & survey, agriculture, and search & rescue, hereby applies for an 

exemption from the Federal Aviation Regulations ("FARs'') to allow commercial operation of its 

UASs. 

Applicant 

Cowles Enterprises, LLC 

4150 San Ysidro Way 

Rockledge, FL 32955 

noah@cirrusaerialphotography .com 

321.586.6442 

Attachment 

DJI Pilot Training 

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

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 91.203 (a) and (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) and (b) 

Extent of relief Cowles Enterprises, LLC seeks, and why: 

14 CFR Part 21 subpart H 
The UAS to be operated carries neither pilot nor passenger and carries no explosive materials or 

flammable liquids. Given the size, weight, speed, and limited operating area associated with the 

aircraft to be utilized, Cowles Enterprises, LLC requests exception. In the restricted environment 

and under the conditions proposed operation will be at least as safe, or safer, than a 

conventional aircraft operating with an airworthiness certificate without said restrictions. 

14 CFR 45.23 (b) 

Due to the size of this UAS it does not have a cockpit, cabin, or pilot station on which to market 

certain words or phrases. Lettering would be very difficult to place on such a small aircraft and 

dimensions would need to be smaller than required minimum. Understanding the importance of 

lettering, Cowles Enterprises, LLC will mark the UAS with the largest possible letters by placing 

the word "Experimental" or assigned number or name, based on request/ruling of FAA, on UAS 

fuselage. The equivalent level of safety will be provided by having the UAS marked on its 

fuselage as required. 

14 CFR 91.7 (a) 

As there will be no airworthiness certificate 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 check list prior to each flight an equivalent level of 

safety will be provided. / 

14 CFR 91.9 (b) (2) 

Given the size and configuration, the UAS has no ability to carry a flight manual on the aircraft. 

There is no room, capacity, or pilot on board to adequately carry flight manual. A equivalent 

level of safety will be maintained by keeping the flight manual at ground control point where 

the pilot will have immediate access to it. 

14 CFR 91.103 

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

needed. Normal procedures including but not limited to; reviewing weather, flight battery 

requirement, landing and takeoff distances, along will all of those found in attachment "DJI Pilot 

Training". An equivalent level of safety will be provided by preflight protocol to properly match 

the machine. 

14 CFR 91.109 

UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is 

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

communications. The equivalent level of safety provided because neither a pilot nor passenger 

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

14 CFR 91.113 (a) and (b) 

Cowles Enterprises, LLC can achieve an equivalent level of safety as achieved by current 

regulations because its UAS does not carry pilot nor passenger. While helpful, a pilots' license 

will not ensure remote control piloting skills. 

14 CFR 91.121 

The UAS may not have a barometric altimeter, but instead does have a GPS altitude read out. 

Cowles Enterprises, LLC believes an exemption may be needed. An equivalent level of safety is 
achieve by the operator receiving live flight data monitoring and confirming current altitude 

along with altitude of launch site shown on GPS altitude indicator. 

14 CFR 91.203 (a) and (b) 

Similar to, 14 CFR 91.9 (b) (2), given the size and configuration, the UAS has no ability to carry 

certificate and registration documents on the aircraft. There is no room, capacity, or pilot on 

board to adequately such documents. An equivalent level of safety will be achieved by keeping 

these documents, to the extent they are applicable to the UAS, at the ground control point 

where pilot has immediate access to them. 

14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (a) 

and (b) 

Given these sections only apply to aircraft with an airworthiness certificate, theses sections do 

not apply to this applicant. As a safety precaution, operator will perform preflight inspections 

and ensure UAS is in working condition before initiating each flight. 

Cowles Enterprises, LLC is seeking relief from all FARs above preventing applicant from 

conducting aerial photography and video taken at levels lessttfan 400ft, at a speed less than 

33.5 mph, and with a maximum flight time of 25 minutes,. The drone to be used is a DJI 

Phantom 2, Plus DJI Phantom 3 Professional or DJI Inspire 1. At 2.8 pounds (DJI Phantom 2 

Plus and Plus DJI Phantom 3 Professional) and 6.5 pounds (DJI Inspire 1), the weight of these 

UAS meets the definition of "small unmanned aircraft" found in section 331. 

The Reform Act 

In order to obtain high quality photography and video the UAS will be used at speeds much less 

than its top speed of 50 mph. Due to the UAS being battery powered there are no combustible 

fuels onboard. The maximum flight time for these particular UASs is approximately 25 minutes 

of battery life and flights will be terminated with 25% battery life remaining. Given the size, 

weight, speed, and limited operating area associated with the aircraft to be utilized Cowles 

Enterprises, LLC finds this exception to be reasonable with an equivalent, or greater, level of 

safety to be reached by the operator. 

Safety 

Please see attachment "DJI Pilot Training" for the safety precautions used for every flight. Aside 

from these practices, Cowles Enterprises, LLC employees will (or will have) receive( d) hands-on 

training prior to piloting any UAS. 

Additionally: 

1) Cowles Enterprises, LLC does not operate within 5 miles of an airport unless prior 

contact to Air Traffic Control or the airport manager has been made; 

2) Cowles Enterprises, LLC lands its UASs prior to manufacturer recommended minimum 

level of battery power; 

3) Cowles Enterprises, LLC pilots its UASs through remote control by line of sight; 

4) Cowles Enterprises, LLC UASs use GPS and a flight safety feature whereby it returns to a 

preprogrammed position and then slowly lands if communication with the remote control 

pilot is lost; 

5) Cowles Enterprises, LLC actively analyzes flight data and other sources of information to 

constantly update and enhance safety protocols; 
~---

6) Cowles Enterprises, LLC conducts extensive pre-flight inspections and protocol, during 

which safety carries primary importance; 

7) Cowles Enterprises, LLC always obtains all necessary permissions prior to operation; 

and, 

8) Cowles Enterprises, LLC has procedures in place to abort flights in the event of safety 

breaches or potential danger. 

Public Interest 

The commercial use of an UAS to conduct image and video collection benefits the general public 

because it is much more efficient than traditional methods of using a plane or helicopter to 

achieve the same result. Cowles Enterprises, LLC can now provide this level of service while 

being conservative with fuel, time, emissions, noise, and other resources. Considering size, 

weight, speed, and absence of combustible fuels, the UAS will pose much less of a safety 

concern for the general public when compared to larger manned aircraft. 

Thank you for your consideration, 

~.-£:z--.- Noah Cowles (managing member) 

Cowles Enterprises, LLC