Joe Louis Cary September 10, 2015

Colorado Cam Copters, LLC

4880 E County Road 64

Wellington, Colorado 80549 USA

UAS Integration Office – Special Rules Coordinator

Federal Aviation Administration

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)

To whom it may concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, 

Joe Louis Cary, operator of small Unmanned Aerial Systems (UAS), hereby applies for an exemption from

the listed Federal Aviation Regulations to allow commercial operation of a small UAS, 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. 

My 35 years experience flying hobby airplanes and helicopters, abiding by the rules of the Academy of Model

Aeronautics (AMA) have instilled a mindset of safety first, as is evident by the safety precautions I take and

how I will operate UAS.

Being a Licensed Private Pilot for 38 years gives me a current and working knowledge of the Federal

Aviation Regulations (FAR’s), Airmans Information Manual (AIM), Notice To Airmen (NOTAM), Aviation

Weather, National Airspace Designation and Usage, and Aircraft Right-of-Way; that pertain to UAS

operation.

Commercial operation small UAS, as described herein, which are equipped with cameras and sensors,

would operate in the following manner:

 Aerial photography or video for commercial / residential roof survey including ;

- Infrared Moisture Scan Technology

- Infrared Heat Loss Profiling

- Recording Storm Disaster Loss Imagery

- Roof inspection of hazardous structure

 Aerial photography or video of Special Events and Scenery

 Aerial photography or video for public and/or private use including real estate,

architecture, land surveys, engineering and other related professional needs.

 Aerial video/photography or providing live video feed and thermal capabilities to assist with

search and rescue operations in cases of an emergency as requested by local authorities.

(1/7)
As described fully below, the requested exemption would permit the operation of small UAS 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, phone, email and address of the applicant:

Name: Joe Louis Cary

Phone: (970) 691-4333

Email: coskydriver59@yahoo.com

Address: 4880 E County Road 64

Wellington, CO 80549

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)

The small UAS I will be using is a multi-rotor craft weighing no more than 55lbs. including payload. 

Under normal conditions they operate at speeds of no more than 45 Mph or 39 Knots and have the ability

hover and move along a vertical and horizontal plane simultaneously. They will operate in line of sight only

and by the exempted person only obeying all other local and federal laws.

Given the small size of the small UAS 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 surrounding the proposed operations and the public benefit,

reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant of

the requested exemption is in the public interest.

AIRCRAFT AND EQUIVALENT 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:

(2/7)
< The small UAS will weigh less than 55 lbs.

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

< 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.

< 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.

< Minimum crew for each operation will consist of the small UAS Pilot in Command (PIC), the Visual

Observer (VO) when needed and may include but not limited to a Camera Operator.

< The small UAS pilot will be Joe Louis Cary, who will not allow any other person to operate the small

UAS in a commercial capacity.

< A briefing will be performed regarding the planned small UAS operations prior to each day’s flight

consisting of all the days’ production activities.

< The PIC 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 or direction of the FSDO, operations at

closer range may be approved.

< The PIC and VO will have been trained in operation of small UAS and receive up-to-date information

for the particular small UAS to be operated and will be able to show upon request their competent

ability to operate the small UAS and/or Camera.

< The PIC and VO will be able to communicate by voice, radio, and/or text at all times.

< 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 when

needed.

< If the small UAS loses communications or loses GPS signal, the small UAS will have the capability

to return to a pre-determined location within a designated location and land autonomously. This is

a safety feature of the UAS we have chosen to fly for this reason.

< The small UAS will have the capability to abort a flight in case of unpredicted obstacles, weather,

or emergencies.

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

Subpart H, entitled Airworthiness Certificates, establishes 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 small UAS. In all cases,

an analysis of these criteria demonstrates that the small 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 (fixed wing or rotorcraft) operating with an airworthiness certificate without the

restrictions and conditions proposed.

The small UAS 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 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. 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 small UAS, 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.

(3/7)
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 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 small UAS will have no airworthiness certificate, an exemption may be needed as the small

UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be

placed. Given the size of the small UAS, 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 small UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and

others working with the small UAS will see the identification of the small UAS as “Experimental.”

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

Pursuant to 14 CFR 61.113 (a), no person who holds a private pilot certificate may act as a pilot in command

of an aircraft that is carrying passengers or property for compensation or hire. Our small UAS do not carry

any pilots or passengers nor property therefore I am seeking an exemption to 14 CFR 61.113(a). Although

helpful with regulations, a pilot’s license will not ensure remote control piloting skills. The risks attendant to

the operation of small UAS 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 small

UAS

.

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. 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 an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft 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 small UAS, 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 small UAS 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 OPERATOR will take all actions including reviewing weather, flight battery requirements,

landing and takeoff distances and aircraft performance data before initiation of flight.

(4/7)
14 C.F.R. §91.109: Flight Instruction.

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. Small UAS 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.

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 small UAS 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 small UAS will never operate at higher than 400 AGL with the exception

that in circumstances where the small UAS is used to survey or photograph a structure whose height exceeds

400 feet AGL, the small UAS will not be operated more than 100' above the highest point on the structure.

It will however be operated in a restricted 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 small UAS 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 small UAS 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 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.” As the small UAS 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 small UAS provides approximately 30 minutes of powered flight. To meet the 30

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

minutes in length. Given the limitations on the small UAS’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. 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

(5/7)
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 small UAS 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 small UAS to its planned landing zone from anywhere

in its limited operating area.

14 C.F.R. §91.203 (a) and (b): Carrying Civil 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 airworthiness 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 small UAS 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 small UAS. An equivalent level of safety will be achieved by keeping

these documents at the ground control point where the pilot flying the small UAS will have immediate access

to them; to the extent they are applicable to the small UAS.

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 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. 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 small UAS can land

immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the small

UAS 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

small UAS Manufacturer's Manual, as referenced in the Aircraft Operations Manual (AOM). As provided in

the FOM, the operator will ensure that the small UAS is in working order prior to initiating flight and perform

required maintenance needed.

Public Benefit:

By utilizing the small UAS to survey roofs and determine heat loss so that energy saving mitigation can occur

and help reduce our carbon footprint; to provide a safe means of roof inspection on otherwise overly

hazardous roof structures; and to help and assist Law Enforcement and Emergency personnel with Search

& Rescue when called upon. As a work tool, the UAS can accomplish many of the same tasks that a full size

aircraft can, but with more safety and economy.

A goal of Colorado Cam Copters, LLC is to be a good ambassador with UAS; calm public concern and

skepticism over safety and privacy issues, integrate UAS into the public eye as a useful tool that can be

viewed as safe and beneficial to all persons.

(6/7)
Small UAS Information:

Small UAS to be used is as follows, but not limited to, providing they are within the

scope of the exemption granted by the FAA:

Manufacturer: Yuneec Electric Aircraft

Model: Typhoon Q500

Weight: 1700 g / 3.75 Pounds

Passenger Capacity: 0 (unmanned)

Size (dimensions): 420x420x240 mm (16.53x16.53x9.45 inches)

Max Speed: 22 mps (72.18 fps / 49.21 mph)

Max Flight Time: 25 minutes

Max Ceiling 400 ft AGL (software limited)

Operations: Line of Sight

Controller: Dedicated Commercial Controller with 2 km maximum rated operating distance

Specifically, the UAS is:

A lightweight (< 7.0 lb gross weight with all on-board equipment), battery operated 4- motor rotorcraft in the

form of a quadcopter that takes off and lands vertically, manufactured by Yuneec, Model Typhoon Q500,

with the following equipment:

< An on-board flight computer with GPS navigation and location ability that receives signals for 

flight controls from a ground-based transmitter/controller; 

< An on-board camera capable of capturing imagery in the form of full color, high definition still 

photos and video;

< An on-board telemetry system that delivers flight data from the on-board flight computer to the 

onboard radio transmitter including altitude AGL, horizontal and vertical speed, compass 

< A 600mW, 5.8GHz on-board radio transmitter that transmits live video from the on-board 

camera plus all the flight data from the telemetry system described above;

The Ground Station Includes:

< A Pilot in Command (PIC) in operational control of a flight operation from beginning to end and 

who controls the UAS while in the air;

< A 100mW, 2.4GHz radio transmitter/controller operated by the PIC to control the UAS while in 

flight;

< A radio receiver receiving live video and flight data from the on-board camera and computer 

projects it all together onto a screen for the PIC to view during flight;

< A Visual Observer (VO)to provide the (PIC) with an additional set of eyes for added safety

Thank you for the consideration of these exemptions. 

Sincerely,

Joe Louis Cary

Colorado Cam Copters, LLC

(7/7)