Ryne Cooper

2515 S Calhoun rd, Unit #101 New Berlin, WI, 53151 (262) 370

-9195 July 20th, 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Subject: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. Part 21, 45.27(a), 45.29 (3) (c)(d)(e)(f)(g)(h), 61.113 (a) & (b), 91.103, 91.119, 91.121, 91.203, 91.151

Following the format of FAA Exemption No. 11138

- R egulatory Docket No. FAA

– 2014

– 0481 I have included: 1) Supplemental Response for Petition 2) Cheerson CX20 User Manual 3) Personal protocols and controls

- Safety/Flight concerns

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, I, Ryne Cooper, preparing this exemption request myself, would like to apply for an exemption fro m the following Code of Federal Regulations (C.F.R) to be allowed commercial op eration of lightweight Unmanned Aircraft Systems (sUAS) for aerial photography and videography. I have experience in flying hobby quads for recreat ional purposes during the past 5 years without incident. I have added a hobby grade Cheerson CX

- 20 quad

- copter (maximum gross weight 3 pounds, equipped with four rot ors that are driven by ele ctric motors powered by batteries, ( the UAS has amaximum airspeed of 20 knots) to my inventory equipped with a Turnigy HD Blac k camera with intent

for aerial videography/ photography to enhance academic community awareness and augment real estate listing videos; following an exemption and approval by the FAA. My exemption request would permit operation of ultra

- light weight, unmanned (piloted by remote control) in predetermined areas away from gene ral public, airports, heliports and vehicular traffic, unde r 300 ft. and after carefully reviewing, inspecting and examining the area of aerial observation. This would allow for community videos and within property boundaries for individual homeowner rea l estate listing videos/photos. I will abide all FAA requirem ents to ensure this exemption will provide a level of safety at least equal to existing rules and will only operate in a safe environment that is strictl y controlled, are away from power lines, elevated lights, airports and actively populated areas; and I will conduct extensive preflight inspecti ons and protocols, during which safety carries primary importance. **14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203** Given the size, weight, speed, and limited operating area associated with t he aircraft to be utilized, I am asking exemption from 14CF Rpart21,Subpart H(Airworthiness Certificates)and§91.203 (a) and (b) (Certifications required), subject to certain conditions and limitations, is warranted and meets the requirem ents for an equivalen t level of safety under14CFRpart 11 and Section 333 of P.L. 112

-95 (Section 333). **14 C.F.R. 45.27(a): Location of marks; non fixed**
**- wing aircraft. 14 C.F.**  **R. 45.29 (3) (c)(d)(e)(f)(h): Size of**  **Marks** Furthermore I request an exemption from §45.23 Marking of the aircraft because my UAS will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Additionally two

- inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal letterin g require ment. I understand the need for markings and will mark my UAS in the largest possibl e lettering by placing the word “Experimental” or assigned number or name (based on a request or ruling by the FAA ) on its fuselage as required by §45.29(f) so th at anyone assisting him as a spotter will see the markings. I also ask for an exemption from §§91.405(a),91.407(a)(1), 91.409 (a)(2) and 91.417(a) and(b) Maintenance inspections may be required and sh ould be granted since they only apply to aircraft with an airworthiness certificate. But, as a safety precaution I will perform a preflight inspection of my UAS before each flight as outlined in his operating documents. **14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command.** Under §61.113 (a) and(b) private pilots are limite d to non

- commercial operations, however I can achieve an equivalent level of safety as achieved by current regulations because my UAS does not carry any pilots or passe ngers. While helpful, a pilots’ license will not ensure remote control piloting skills. The risks of operating a UAS are far less than the risk levels inherent in the commercia l activities outlined in 14 CFR part61,et seq., I requests an exemption from §61.1 13 Private Pilot Privileges and Limitation s. Aside note, I have already explored getting my pilot’s license, at the direction of the FAA, I would gladly

begin education and eventual licensing. Regarding UAS operational training, a s stated previously I have five years’ experience flying numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of his UAS’ performance under different temperature and wea ther conditions. I also own and practices on a computeri zed simulated flights software to maintain adequate skills and response reflex time. I’m also aware of a three

- day dro ne training course in Las Vegas Nevada and would gladly attend if required by the FAA. **14 C.F.R. 91.103 (b)(1), (b)(2): Preflight Action**
I f granted an exemption I agree to additional safety proced ures including, but not limited to: 1) Keeping my USA within a radius distance of 1000 feet from the controller to both aid in direct line of sight visual observation. 2) Operate the UAS for 3

-7 min utes per fligh t; land my UAS according to the manufacturer’s recommended minimum level of battery power. 3) Operate my UAS only within visual line of sight (VLOS). 4) Use the UAS’ global positioning system(GPS) fligh t safety feature; it hovers and then slowly lands if communication with the remote control. 5) Conduct all operations under my own perso nal and flight safety protocols (including posting a warning sign reading: “Attention Aerial Photography in Progress

– Remain Back 150 feet”). 6) I will operate and will actively analyze flight data a nd other sources of information to constantly update and enhance my safety protocols. 7) Contact respective airports if operations will be w ithin 5 miles to advise them of his estimated flight time, flight duration, e levatio n of flight and other pertinent information. 8) Always obtain all necessary permissions prior to operation. 9) Have procedures in place to abort flights in the event of safety breaches or potential danger. Aerial videography for geographical awarene ss of real estate marketing has been around for a long time through manned fixed winged aircra ft and helicopters, but for small business owners, its expense has been cost

- prohi bitive. Granting this exemption would allow me to provide this service at a much lower cost. Further, my small UAS, when used properly, will pose no threat to the public give n its small size and lack of combustible fuel when compared to larger manned aircraft. The operation of his UAS will minimize ecological damage and promote econom ic growth by providing information to companies looking to relocate or build in the Wisconsin area.One final comment, the use of a UAS has already prove n to increase the marketability of a home. For

example please review the article publi shed January 7, 2015 in the San Diego source entitled “drone use in real estate may increase”. The article cites the FAA’s exemption given to Douglas Trudeau, but also describes a record high price for an area ho me that used a drone for aerial photography. “When broker Ku rt Wannebo added an aer ial video to the listing for a Carmel Valley house, located on a large corner lot overlooking canyons on two sides, he saw Web traffic noticeably increase.” I understand this may be outside the scope of this reque st but as a previous home owner I think it’s important to point out that the use of any tool th at increases value to a home or community (by adding visibility to more potential buyers) is in the best interest of homeowners nationwide. Selling a home faste r and fo r more money because of the use of new technology (being safely used and approved by the FAA) will go a long way to ensure our economy continues to grow.