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 -Regulatory 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 from the following Code of Federal Regulations (C.F.R) to be allowed commercial operation 

of lightweight Unmanned Aircraft Systems (sUAS) for aerial photography and videography.

I have experience in flying hobby quads for recreational 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 rotors that are driven by electric motors powered by batteries, (the UAS has a 
maximum airspeed of 20 knots) to my inventory equipped with a Turnigy HD Black 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 general public, airports, heliports and vehicular traffic, under 

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 real estate listing 

videos/photos. I will abide all FAA requirements 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 strictly controlled, are 

away from power lines, elevated lights, airports and actively populated areas; and I will conduct 

extensive preflight inspections 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 the aircraft to be utilized, I am 

asking exemption from 14CFRpart21,Subpart H(Airworthiness Certificates)and§91.203 (a) and (b) 

(Certifications required),subject to certain conditions and limitations, is warranted and meets the 

requirements for an equivalent 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 lettering 

requirement. I understand the need for markings and will mark my UAS in the largest possible 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 that 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 should 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 limited 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 passengers. 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 commercial activities outlined in 

14 CFR part61,et seq., I requests an exemption from §61.113 Private Pilot Privileges and Limitations. A 
side 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, as 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 

weather conditions. I also own and practices on a computerized simulated flights software to maintain 

adequate skills and response reflex time. I’m also aware of a three-day drone 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

If granted an exemption I agree to additional safety procedures 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 minutes per flight; 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) flight safety feature; it hovers and then slowly lands if 

communication with the remote control.

5) Conduct all operations under my own personal 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 and other sources of information to constantly 

update and enhance my safety protocols.

7) Contact respective airports if operations will be within 5 miles to advise them of his estimated flight 

time, flight duration, elevation 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 awareness of real estate marketing has been around for a long time 

through manned fixed winged aircraft and helicopters, but for small business owners, its expense has 

been cost-prohibitive. 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 given 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 economic 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 proven to increase the marketability of a home. For 

example please review the article published 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 home that used a drone for aerial photography. “When broker 

Kurt Wannebo added an aerial 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 request but as a previous home owner I think it’s 

important to point out that the use of any tool that 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 

faster and for 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.