April 9, 2015

Exemption No. 11314 Regulatory Docket No. FAA–2014–0958

Mr. Ryan K. Koffman 12289 Daisy Court Rancho Cucamonga, CA 91739
Dear Mr. Koffman: This letter is to inform you that we have gran ted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.
The Basis for Our Decision By letter dated November 13, 2014 1 , you petitioned the Federal Aviation Administration (FAA) for an exemption. The exemption would allow the petitioner to operate an unmanned aircraft system (UAS) to c onduct aerial photography and/or video, training, and closed-set filming. See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner.

1 By email dated March 12, 2015, the petitioner stated its intent to use an unmanned aircraft system for closedset filming.2
Airworthiness Certification The UAS proposed by the petitioner is a DJI Inspire 1. The petitioner requested relie f from 14 CFR part 21, C ertification procedures for products and parts, Subpart H—Airworthiness Certificates . In accordance with the statutory criteria provided in Section 333 of Public Law 112

í 95 in reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transp ortation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 14 CFR part 21, and any associated noise certifi cation and testing requirements of part 36, is not necessary.
The Basis for Our Decision You have requested to use a UAS for aerial data collection and closed set motion picture and filming. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption Nos. 11062 to Astraeus Aerial ( see 'RFNHW1R)$$ííWR&OD\FR,QF see Docket No. FAA

í 2014

í 0507), 11112 to VDOS Global, LLC ( see 'RFNHW1R)$$ííDQG 11213 to Aeryon Labs, Inc. ( see 'RFNHW1R)$$ííWKH)$$IRXQGWKDWWKH enhanced safety achieved using an unmanned airc raft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest. Having reviewed your reasons for requesting an exemption, I find that—

x They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213;

x The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and

x A grant of exemption is in the public interest.
Our Decision In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Mr. Ryan K. Koffman is granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) a nd (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1 ) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection and closed set motion picture and filming. This exemption is subject to the conditions and limitations listed below.3
Conditions and Limitations In this grant of exemption, Mr. Ryan K. Koffm an is hereafter referred to as the operator. Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption. 1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when weighing less than 55 pounds including pa yload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption. 2. Operations for the purpose of closed-set motion picture and television filming are permitted. 3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restricti on. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer. 4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use hum an vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or U.S. driver’s license. 6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO. 7. This exemption and all documents need ed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepa ncy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed.4 Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revi se its operating documents. It is the operator’s responsibility to track such re visions and present updated and revised documents to the Administrator or any la w enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which th e FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be contacte d if questions arise regarding updates or revisions to the operating documents. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacemen t of a flight critical component, must undergo a functional test flight pr ior to conducting further operations under this exemption. Functional test flights may onl y be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functi onal test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property. 9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. 10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable co mponents, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. 11. The operator must follow the UAS ma nufacturer’s maintenance, overhaul, replacement, inspection, and life limit require ments for the aircraft and aircraft components. 12. Each UAS operated under this exemption mu st comply with all manufacturer safety bulletins. 13. Under this grant of exemption, a PIC mu st hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet th e flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PI C is rated on his or her pilot certificate. 14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be5 operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons , vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-buildin g flights, all persons not essential for flight operations are considered nonpartic ipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducte d under visual meteorological conditions (VMC). Flights under special visual flight rule s (SVFR) are not authorized. 16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facilit y Directory (AFD) or for airports not denoted with an ARP, the center of the ai rport symbol as denoted on the current FAApublished aeronautical chart, unless a lette r of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request. 17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.
18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the pr ivate or controlled-access property. 19. The PIC must abort the flight in the even t of unpredicted obstacles or emergencies. 20. The PIC is prohibited from beginning a fl ight unless (considering wind and forecast weather conditions) there is enough ava ilable power for the UA to conduct the intended operation and to operate after that for at least fi ve minutes or with the reserve power recommended by the manufacturer if greater. 21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accord ance with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted unde r the terms of the attached COA. 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N-6 Number) markings in accordance with 14 CF R part 45, Subpart C. Markings must be as large as practicable. 23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 24. The UA must remain clear and give wa y to all manned aviation operations and activities at all times. 25. The UAS may not be operated by the PIC from any moving device or vehicle. 26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles , and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicl es or structures has granted permission for operating closer to those objects and th e PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PIC, VO, operator trainees or e ssential persons are not considered nonparticipating persons under this exemption. 27. All operations shall be co nducted over private or cont rolled-access property with permission from the property owner/cont roller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as define d by the applicable COA must be reported to the FAA's UAS Integration Office (AFS- 80) within 24 hours. Accidents must be reported to the National Tr ansportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. If this exemption permits operations for the purpose of closed-set motion picture and television filming and production, the following additional conditions and limitations apply.7 29. The operator must have a motion pictur e and television opera tions manual (MPTOM) as documented in this grant of exemption. 30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day notification may be waived with the concur rence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights; b. Name and phone number of the operato r for the UAS aerial filming conducted under this grant of exemption; c. Name and phone number of the person re sponsible for the on-scene operation of the UAS; d. Make, model, and serial or N-Number of UAS to be used; e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obt ained permission from property owners and/or local officials to conduct the f ilming production event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemption hol der or representative; and h. A description of the flight activity, incl uding maps or diagrams of any area, city, town, county, and/or state over which f ilming will be conducte d and the altitudes essential to accomplish the operation. 31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary fo r the filming production, as specified in the exemption holder’s MPTOM. Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. This exemption terminates on April 30, 2017, unless sooner superseded or rescinded. Sincerely,

/s/ John Barbagallo Acting Deputy Director, Flight Standards ServiceRyan K. Koffman 12289 Daisy Court Rancho Cucamonga, CA 91739-1921 November 13, 2014

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)

Dear Sir or Madam:
Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Ryan K. Koffman, operator of Small Unmanned aircraft Systems (“sUAS”), hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUAS, so long as such operations are conducted within and under the conditions outlined herein or as my be established by the FAA as required by Section 333.
Commercial operation sUAS, 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 activities. 2. Aerial video and/or photography for public and/or private use including television, public events, cinematography and news gathering. 3. Aerial inspection/photography of residential/comme rcial structures under contract with 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. 5. The ability to offer training to persons individually or belonging to both private and/or public organizations that have interests in the use and application of sUAS for the purpose of the safe operation of sUAS to enhance the safety of the National Airspace System (NAS) as well as for the protection of the persons and property.U.S. Department of Transportation November 13, 2014 Page 2

As described fully below, the requested exemption would permit the operation of sUAS under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide 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 requirements for the safe operation of such aircraft systems in the national airspace system.”
The name and address of the applicant is:
Attn: Ryan K. Koffman Ph: 909-899-0193 Email: rcoconut@yahoo.com Address: 12289 Daisy Court, Rancho Cucamonga, CA 91739-1921
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)

My sUAS are multi-rotor craft weighing no more than 55lbs. including payload. Under normal conditions they operate at speeds of no more than 50kts and have the ability hover and move along a vertical and horizontal plane simultaneously. They will operate in line of sight and will operate within a closed off and predetermined area owned and/operated by the property representative.
Given the small size of the sUAS and the controlled environment 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 surrou nding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant ofU.S. Department of Transportation November 13, 2014 Page 3

the requested exemption is in the public interest. Accordingly the applicant requests that the FAA grant the requested exemption with minimum delay.

AIRCRAFT AND EQUIVALE NT LEVEL OF SAFETY
The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property using conventional aircraft.
These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) 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 flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes of flight time whichever occurs first. 4. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned. 5. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer (VO) and may include but not limited to a Camera Operator. 6. The sUAS pilot will be a designated Pilot in Comma nd (PIC) and hold a current Third or higher Class Medical Certificate, along with a valid state driver’s license. If the PIC feels another operator to be qualified with the necessary skills to be PIC & po ssess a Third or higher Class Medical and a valid state driver’s license, that person may be designated PIC provided they have a minimum of 20 hours of flight time with the sUAS. 7. A briefing will be performed regarding the planned sUAS operations prior to each day’s flight consisting of all the days’ production activities. 8. The operator will file FAA Form 7711-1, or its equivalent, as modified in light of the requested exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours but no less than 48 hours from planned operation. 9. The operator will obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as required under the FOM. With the advanced permission of the FSDO, operations at closer range may be approved. 10. The PIC and VO will have been trained in operation of sUAS and receive up-to-date information for the particular sUAS to be operated. 11. The PIC and VO will be able to communicate by voice, radio, and/or text at all times. 12. Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate governmental agencies. 13. If the sUAS loses communications or loses GPS signal, the sUAS will have the capability to return to a pre-determined location within a designated location and land autonomously. 14. The sUAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies.U.S. Department of Transportation November 13, 2014 Page 4

14 C.F.R. Part 21, Subpart H: Airworthines s Certificates 14 C.F.R. §91.203 (a) (1)
Subpart H, entitled Airworthiness Certificates, establis hes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). 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 fu els, 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. The FAA will have advance notice of all operations. These safety enhancements 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: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experiment al 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, 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 sUAS, two-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 as “Experimental.”
14 C.F.R. § 61.113 (a): Private Pilot Privileges and Limitations: Pilot in Command.U.S. Department of Transportation November 13, 2014 Page 5

Pursuant to 14 CFR 61.113 (a), no person who holds a pr ivate pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire. Our sUAS do not carry any pilots or passengers nor property therefore I am seekin g an exemption to 14 CFR 61.113(a). Although helpful, a pilot’s license will not ensure remote control piloting skills. The risks attendant to the operation of sUAS is far less than the risk levels inherent 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 sUAS.
14 C.F.R. §91.7(a): Civil Aircraft Airworthiness.
The regulation requires that no person may operate a civ il aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the ai rcraft, 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 lists prior to each flight an equivalent le vel of safety will be provided.
14 C.F.R. § 91.9 (b) (2): Civil Aircra ft Flight Manual in the Aircraft.
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. 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.
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 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.
Section 91.103 provides that no person may operate a ci vil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. sUAS 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. 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.U.S. Department of Transportation November 13, 2014 Page 6

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. 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' abov e 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 give n 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 addition, the low-altitude 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.
This regulation requires each person operating an aircra ft 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 sUAS 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 least 45 minutes.”
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 woul d 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 co nditions 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 officialU.S. Department of Transportation November 13, 2014 Page 7

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 eq uivalent 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.
14 C.F.R. §91.203 (a) and (b): Carrying Civ il 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 unless the airw orthiness certificate required by paragraph (a) of 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.
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 registra tion 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.
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 aircraft 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 pa rt 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. 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 beca use maintenance and inspections will be performed in accordance with the sUAS Manufacturer's Manual, as refe renced in the Aircraft Operations Manual (AOM). AsU.S. Department of Transportation November 13, 2014 Page 8

provided in the FOM, the operator will ensure that the sUAS is in working order prior to initiating flight and perform required maintenance needed.

Additional Information
The applicant, Ryan K. Koffman, has been involved in the building and piloting of remote controlled aircraft for more than 10 years. Also the primary pilot, Ryan K. Koffman, is an FAA Commercial Licensed Airline Transport Pilot with a First Class Medical.
Satisfaction of criteria provided in Section 333 of the Reform Act of 2012 provide more than adequate justification for the grant of the requested exemptions allowing the commercial operation of the applicant’s sUAS.

Sincerely,

Ryan K. Koffman