July 

### 27th, 2015

U. S. Department ofTransportation Docket Management System 

### 1200 NewJersey Ave., Washington, DC 

### 20590

RE: Exemption Request Section 

### 333 ofthe FAA Reform Act and Part 

### 11 ofthe Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 

### 333 ofthe FAA Modernization and Reform Act of

### 2012 (the "Reform Act'') and 

### 14 C.F.R. Part 

### 11, Cowles Enterprises, LLC, an operator ofUnmanned Aircraft Systems ("UAS'') for aerial data acquisition including but not limited tothe 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 ofits UASs.
Applicant Cowles Enterprises, LLC 

### 4150 San Ysidro Way Rockledge, FL 

### 32955 noah@cirrusaerialphotography.com 

### 321.586

.6442

Attachment DJI PilotTraining
Regulationsfrom which theexemption 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)

ExtentofreliefCowles Enterprises, LLC 

### seeks, and why:

14CFR Part 21 subpart HThe 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 underthe conditions proposed operation will be at least as safe, or safer, than a conventional aircraft operating with an airworthiness certificate without said restrictions.



### 14CFR45.23(b) Due to the size ofthis UAS itdoes not have acockpit, cabin, or pilotstation on which to market certain words or phrases. Lettering would be very difficultto place on such asmall aircraft and dimensions would need to be smallerthan required minimum. Understanding the importance of lettering, Cowles Enterprises, LLC will markthe UAS with the largest possible letters by placing the word "Experimental" or assigned number or name, based on request/ruling ofFAA, on UAS fuselage. The equivalent level ofsafety will be provided by having the UAS marked on its fuselage as required.



### 14CFR91.7 (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 ofthe aircraft for maintenance and use ofsafety check list priorto each flight an equivalent level of safety will be provided. /



### 14CFR91.9 (b) (2) Given the size and configuration, the UAS has no ability to carry aflight manual on the aircraft. There is no room, capacity, or pilot on board to adequately carry flight manual. Aequivalent level ofsafety will be maintained by keeping the flight manual at ground control point where the pilot will have immediate access to it.



### 14CFR91.103 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 ofthose found in attachment "DJI Pilot Training". An equivalent level ofsafety will be provided by preflight protocol to properly match the machine.



### 14CFR91.109 UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved through the use ofacontrol box that communicates with the aircraft via radio communications. The equivalent level ofsafety provided because neither a pilot nor passenger will be carried in the aircraft, and by the speed and size ofthe aircraft.



### 14CFR91.113 (a)

### and (b) Cowles Enterprises, LLC can achieve an equivalent level ofsafety as achieved by current regulations because its UAS does notcarry pilot nor passenger. While helpful, a pilots' license will not ensure remote control piloting skills.



### 14CFR91.121 The UAS may not have a barometric altimeter, but instead does have aGPS altitude read out. Cowles Enterprises, LLC believes an exemption may be needed. An equivalent level ofsafety isachieve by the operator receiving live flight data monitoring and confirming current altitude along with altitude of launch site shown on GPS altitude indicator.



### 14CFR91.203(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 ofsafety will be achieved by keeping these documents, to the extentthey are applicable to the UAS, atthe ground control point where pilot has immediate access to them.



### 14CFR91.405(a), 14CFR91.407(a) (1), 14CFR91.409 (a) (2), 14CFR91.417(a) and (b) Given these sections only apply to aircraftwith an airworthiness certificate, theses sections do not apply to this applicant. As a safety precaution, operatorwill perform preflight inspections and ensure UAS is in working condition before initiating each flight.

Cowles Enterprises, LLC is seeking relieffrom all FARs above preventing applicantfrom conducting aerial photography and video taken at levels lessttfan 400ft, at a speed less than 33.5 mph, and with a maximum flighttime of25 minutes,. The droneto 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 ofthese UAS meets the definition of "small unmanned aircraft" found in section 331.

The Reform Act In orderto obtain high quality photography and video the UAS will be used atspeeds much less than itstop speed of50 mph. Due tothe UAS being battery powered there are no combustible fuels onboard. The maximum flighttime forthese 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 aircraftto 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 PilotTraining" forthe safety precautions used for everyflight. Aside from these practices, Cowles Enterprises, LLC employees will (orwill have) receive(d) hands-on training priorto piloting any UAS.

Additionally: 1) Cowles Enterprises, LLC does not operate within 5 miles ofan airport unless prior contact to Air Traffic Control orthe airport manager has been made; 2) Cowles Enterprises, LLC lands its UASs priorto manufacturer recommended minimum level of battery power; 3) Cowles Enterprises, LLC pilots its UASs through remote control by line ofsight; 4) Cowles Enterprises, LLC UASs use GPS and a flight safety feature whereby it returns to a preprogrammed position and then slowly lands ifcommunication with the remote control pilot is lost; 5) Cowles Enterprises, LLC actively analyzes flight data and other sources ofinformation 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 priorto operation; and, 8) Cowles Enterprises, LLC has procedures in place to abortflights in the event ofsafety breaches or potential danger.

Public Interest The commercial use ofan UAS to conduct image and video collection benefits the general public because it is much more efficient than traditional methods ofusing a plane or helicopterto achieve the same result. Cowles Enterprises, LLC can now provide this level ofservice while being conservative with fuel, time, emissions, noise, and other resources. Considering size, weight, speed, and absence ofcombustible fuels, the UAS will pose much less ofasafety
concern forthe general public when compared to larger manned aircraft.

Thankyou foryour consideration,



# ~.-£:z--.- Noah Cowles (managing member) Cowles Enterprises, LLC