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November 17, 2015
Daniel R. Cournoyer Dba: Maine Drones 16 Fairview Drive Lisbon, ME 04250 Danc16f@hotmail.com 207

- 577

- 7783
U. S. Department of Transportation 1200 New Jersey Avenue, SE West Building, Ground Floor, Room W12

- 140 Washington, D.C. 20590

RE: Daniel R. Cournoyer’s Petition for Exemption from Federal Aviation Regulations for the purpose of operati ng an Unmanned Aircraft System.

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. Part 11, Daniel R. Cournoyer seeks an exemption from Federal Aviation Regulations to allow the commercial use of the DJI Inspire 1 Unmanned Aircraft System (UAS) to conduct aerial video graphy and photography of a ny business, construction site, real estate, landscapes, structure inspections, and events within the National Airspace System (NAS).
Daniel R. Cournoyer has a Commercial Pilot License (ASEL) with an Instrument Rating and will be renewing his medical cert ificate in the very near future. Daniel R. Cournoyer has already applied to the FAA for a certificate of registration for his DJI Inspire 1 UAS. He also has 12 years of experience as a technician on Motion Pictures, TV shows and National Commercials.2

Daniel R. Cournoyer seeks relief from the following R egulations:

14 CFR Part 21 14 CFR 45.23(b) 14 CFR 61.113(a) and (b) 14 CFR 91.7(a) 14 CFR 91.119(c) 14 CFR 91.121 14 CFR 91.151(a)(1) 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)
Aircraft and Equivalent Level of Safety
The DJI Inspire 1 UAV will be operated by Daniel R. Cournoyer. The operating limitations proposed by Daniel R. Cournoyer provide for at l east an equivalent or higher level of safety than when using conventional passenger aircraft for videography and photography. 1. The UAS will weigh less than 55 lbs

. 2. Flights will be operated within visual line of s ight (VLOS) of a pilot and/or observer

. 3. Prior to each flight the Pilot will conduct a Pre

-flight Safety Inspection of the aircraft and will comply with all manufacturer safety bull etins. 4. M aximum flight time for each operational flight will be 18 minutes of less. Flights w ill be terminated at 30% battery power reserve

. 5. Flights will be operated at an altitu de of no more than 400 feet AGL and at a maximum speed of 49 mph. 6. M inimum crew for each flight will consist of the UAS Pilot who will be Pilot in Command (PIC) and a Visu al Observer(VO).3

7. The UAS will operate within a confined sterile area with a set safety perimeter, the boundaries of which will be determined by UAS PIC based on the site specific activities and speed of the UAS required for the particular 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 UAS operations at the beginning of each day. It will be mandatory for all personnel performing duties within t he boundaries of the safety perimeter be present at this briefing. 9. The UAS pilot will i nsure this safety perimeter by allowing only consenting personnel within close proximity of the UAS operation and not permitting anyone who has not been briefed or is not part of the production to be in the confined sterile area . 500 feet will be maintained from people not directly involved in the production. 10. T he Pilot and VO will at all times be able to communicate by voice and/or two way radio. 11. Written and/or oral per mission from the relevant property holders will be obtained. 12. If applicable, all required permissions and permits will be obtained from territorial, state, county, or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 13. If the UAS loses communications or loses its GPS signal, the UAS has the capability to return to a predetermined location and land safely. The PIC will verify that the three safe modes (Return to Home, F ailsafe, and Dynamic Home Poin t) on the Inspire 1 are functioning properly. 14. The PIC will abort the flight in case of emergencies or unforeseen obstacles. 15. The UAS will not be operated less than 500 feet below or less than 2000 feet horizontally from a cloud. Visibility must be at least 3 statute miles from the PIC. 16. No UAS flights will occur within 5 nautical miles of an airport unless prior permission is obtained from the local Flight Standards District Office. 17. The PIC must meet all flight review requirements and hol d a current medical certificate. 18. The PIC must meet the minimum flight hour requirements in this particular UAS and demonstrate its safe operation.

Reasons why granting this exemption would be in the public interest. The UAS will increase safety for the public because of its small size, less weight and lack of combustible fuel when compared to larger manned aircraft currently performing aerial photography, v ideography and/or data collection

. The public will benefit by a decrease in congestion of the NAS. The public will benefit by a reduction in pollution because the UAS has electric motors.4

The public will benefit economically because it will be more cost effective for businesses to hire a UAS than a manned aircraft. The public will benefit because there are no privacy issues . The UAS flights will only occur over private and/or controlled access property, with the landowner’s prior consent and knowledge.

Basis for Petition
14 CFR Part 21, Subpart H: Airworthiness Certificates Given the size and limited operating area associ ated with the UAS to be utilized by Daniel R. Cournoyer, an E xemption from CFR 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. Section 44701 (f) and S ection 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement of an airworthiness certificate, upon consideration of size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS 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 (fixe d wing or rotorcraft) operating with an airworthiness certificate and without the conditions and restrictions proposed.
14 CFR 45.23(b) Display of Marks Because the DJI Inspire 1 does not have a cabin, cockpit or pilot station Daniel R. Cournoyer request s relief. The body of the aircraft will be marked with an N number as large as practicable.
14 CFR 61.113(a) and (b). Private pilot privil eges and limitations: Pilot in Command Daniel R. Cournoyer requests relief from Section 61.113(a) and (b) to the ext ent necessary to allow a person who holds a private pilot or higher level certificate, as well as a current and valid medical certificate, and who has met certain flight hour and currency requirements, to operate the UAS for compensation or hire. Daniel R. Cournoyer submits that a n equivalent level of safety will be maintained because no PIC will be allowed to operate The DJI Inspire 1 UAS unless the PIC has met flight hour and currency requirements and demonstrates that he can safely operate the UAS in a manner consistent with operations specifications as described in this5

exemption request. These include evasive and e mergency maneuvers, as well as maintaining appropriate distances from people, vehicles, vessels and structures.

14 CFR 91.7(a) Civil Airc raft Airworthiness Daniel R. Cournoyer seeks relief from Section 91.7(a) which states that “no person may operate a civil aircraft unless it is in an airworthy condition,” because the DJI Inspire 1 does not require an airworthiness certificate in accordan ce with CFR Part 21, Subpart H. Daniel R. Cournoyer submits the PIC will ensure the UAS is in condition for safe flight by determining that the UAS is in compliance with the DJI Inspire 1 Maintenance Manuel and a complete inspection of the aircraft and its systems is performed before each flight. A monthly Maintenance Log will be kept for the aircraft.
CFR 91.119(c) Minimum Safe Altitudes Daniel R. Cournoyer seeks relief from Section 91.119 because operations conducted at 400 feet AGL or l ower will require the UAS to be operated closer than 500 feet to essential persons or objects. An equivalent level of safety will be maintained because the UAS operates without people or fuel on board thus reducing the likelihood of death or serious bodily injury t o persons in the air or on the ground, as well as reducing the risk of damage to vessels, vehicles and structures. Permission will be obtained from property owners and persons on the ground before operations.
14 CFR 121 Altimeter Settings Daniel R. Courn oyer seeks relief from Section 121 because the UAS does not have a typical barometric altimeter. An equivalent level of safety can be met because the altitude of the UAS is provided to the PIC through the aircraft’s GPS equipment and radio communications t elemetry data link, which downlinks altitude information to the ground control system for active moni toring of the flight path. This information is sufficient for the PIC to maintain the UAS at an altitude below the 400 feet AGL limitation.
14 CFR 91.151( a)(1) Fuel Requirements for flight in VFR conditions. Daniel R. Cournoyer seeks relief from Sect ion 91.151(a)(1) because the total flight time for the DJI Inspire 1 is 18 minutes maximum. An equivalent level of safety will be maintained because the UAS will terminate its flight when 30% of battery power remaining is reached.6

14 CFR 91.405(a) , 91.407(a)(1), 91.409(a)(1)and (2), and 91.417(a) and (b) Daniel R. Cournoyer seeks relief from sections 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417( a) and (b)

. Since these Sections set forth requirements for maintenance that only apply to an aircraft with an airworthiness certificate. Daniel R. Cournoyer submits that the requested relief is proper since an equivalent level of safety will be ensured d ue to the following: Routine Maintenance, Preventative Maintenance and/or alterations to the UAS will be performed using the methods specified in the Manufacture’s Maintenance Manual. After any maintenance or alterations a functional flight test will be conducted before any further operations. Daniel R. Cournoyer will document and maintain all maintenance records on the UAS and will comply with all of the manufacturer’s safety bulletins.
Specifications of the DJI Inspire 1 UAS Model: T600 Weight: 2935 g (Battery included) or 6lbs. 7.5 oz Maximum speed: 49mph Maximum flight time: 18minutes Dimensions: 438x451x301 mm Motor: DJI 3510 (four total, electric) T he FAA has issued grants of exemption in circumstances similar to those presented in this petit ion (13428, 13302, 13309, 13439, and 13443).

Please find the User Manual, Quick Start Guide, Safety Guide, and Intelligent Flight Battery Guide for the DJI Inspire 1 aircraft: www.dji.com/product/inspire

- 1/download
Respectfully, Daniel R. Cournoyer7