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Scott Cooper , Section 333 Exemption Petition

31 July, 2015

10265 W. Patrick Lane 

Peoria , AZ 85383

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal 

Aviation Regulations from 14 C.F.R.45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 

61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 

91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

To Whom It May Concern:

I, Scott Cooper, am writing pursuant to the FAA Modernization and Reform Act of 

2012 and the procedures in 14 C.F.R. 11, to request that I, Scott Cooper, may 

operate my small unmanned aircraft systems (UAS) in commercially regulated 

airspace by the Federal Aviation Administration (FAA).

I, Scott Cooper, have been flying UAS for recreational purposes for the past 3

years. I have experience in flying hobby planes, drones, and helicopters. In the 

3 years, I have flown without incident and pledge my continued commitment to 

safety on all future flights. With the exemption and approval by the FAA, I, Scott 

Cooper, will use my DJI Inspire 1, DJI Phantom 3 as a professional aerial 

filmmaking platform / Safety Inspection for the following applications: for real 

estate/Realtor purposes, Search and Rescue, agricultural field monitoring, 

land/trusts inspections, structure inspections, film/video productions, Cell Tower 

/ Two way Radio Safety Inspections / Bridge or Infrastructure Safety Inspections.

I. Safety, Design, and Operations

The DJI Inspire 1, DJI Phantom 3 that I will be using for videography will be safely 

conducted to minimize risk to NAS, people and property on the ground and in the air. 

The Inspire 1, Phantom 3 are professional aerial film making platforms. The advanced 

flight controller makes the Inspire 1, Phantom 3 stable, safe, and easy to fly. The 

Vision Positioning system, on the Inspire 1 and Phantom 3, gives it the power to hover 

in position at low altitudes even without GPS. The UASs are able to return home if the

remote controller signal is lost or if the low battery warning is triggered. They are

equipped with an onboard camera. The Inspire 1 has a maximum flight speed of 22m/s

(no wind), and a maximum flight time of 18 minutes using one fully charged 4500mAh 
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Intelligent Flight Battery. The Phantom 3 has a maximum speed of 10m/s (no wind), 

and a maximum flight time of 18 minutes using one fully charged 4480mAh Intelligent 

Flight Battery. I have programmed the UASs to give me an automatic low battery 

warning at 30%, and at 10%, they will automatically RTL (return to launch). I, Scott 

Cooper have personally installed safety protocols and regulations exclusive to 

lightweight UAS’s for specific video usage by sharing information with the FAA as I, 

Scott Cooper , record flight data and other important information gained through 

permitted flight operations. I, Scott Cooper will be cognitive of surroundings by 

checking for people, power lines, etc. 

On the DJI website (http://www.dji.com/product/inspire-1 ) when describing the Inspire 

1 and Phantom 3 it states, “As it flies, the position of your Inspire 1 is constantly 

updated and recorded using a high-strength, intelligent GLONASS + GPS system. This 

dual positioning system enables higher precision and quicker satellite acquisition, 

allowing you to see where the aircraft is on a live map and giving it a point to hover at 

when you release the controls. In additional to traditional GPS, GLONASS offers an even 

greater level of precision by providing even more satellites. The Inspire 1 even 

remembers its takeoff point and dynamically tracks your current position, so you can 

bring your Inspire 1 back to you at the press of a button.” 

The DJI Inspire 1, DJI Phantom 3 also feature Electronic Speed Controllers (ESCs) that 

handle communication between the Main Controller and motors. “They tell each motor 

exactly how fast to spin and how much power to use at all times. As you fly and 

maneuver around, each motor moves at its own speed as calculated by DJI’s advanced 

algorithms, giving you complete control” (DJI, 2015, website). 

The fail-safe feature on the Inspire 1, Phantom 3 assist them in landing before an 

accident can occur. “If the battery runs low or connection with your remote controller is 

lost, the Inspire 1 uses its positioning system and smart flight technology to return back 

to you” (DJI, 2015, website). 

The Inspire 1, Phantom 3 are steady and stable during flight, because the advanced 

Inertial Measurement Unit (IMU) handles everything. “The IMU incorporates both a 6-

axis gyroscope and an accelerometer to monitor miniscule changes in tilt and 

movement. This allows the aircraft to compensate and adjust immediately, holding its 

position at all times” (DJI, 2015, website). Because of the DJI Inspire 1, DJI Phantom 3

advanced technology in maintaining a stable flight, the chances of losing control over 

the UAS are slimmer; thus, making the UASs a safer UAS then most. 

The small UASs will not only be a benefit to me, Scott Cooper, commercially, but it will 

also play a positive role in reducing Risk and improving Safety for Cell Tower / Two 
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way Radio Mountain top inspection teams. My light weight UASs are battery powered 

and creates no emissions that can harm the environment. 

II. Procedures and Inspections

I, Scott Cooper, use a fully charged battery with each flight as a safety precaution. The 

Inspire 1 and Phantom 3’s full flight time limit for each battery is approximately 20mins. 

I fly at a limit of 7-10 minutes on the Inspire 1 and Phantom 3 on each battery, 

preferring to remain well within a safe operating range to insure adequate 

communication between radio control and UAS. Reserve batteries are always on hand 

with each flight, to insure replacement for sufficient safe level of operation. 

Before switching the Inspire 1, Phantom 3 on for calibration and parameter setting, I, 

Scott Cooper, check/remove all propellers/wings to ensure the safety of myself and 

others. I, Scott Cooper, check all connections and keep other people, animals, or 

obstructions a safe distance away during firmware upgrades, system calibration, and 

parameter setting. When putting my propellers/wings on the Inspire1, Phantom 3, I 

check to make sure they’re tight before flight. Before flight, I check for damaged or 

worn propellers/wings, batteries, and other parts that should be replaced or repaired. I 

check to make sure the flight battery, remote controller, Wi-Fi range extender, and all 

other necessary items are fully charged. 

III. Specifications 

The Inspire 1 and Phantom 3’s operating frequency is 2.400~2.483 GHz for the flight 

controls. 

According to the DJI website on the Inspire 1 aircraft, it has the following 

specifications:

Model: T600, Weight: 2935 g (about 6.47 pounds), Hovering Accuracy (GPS Mode): Vertical0.5m and Horizontal- 2.5m, Max Angular Velocity: Pitch- 300°/s and Yaw- 150°/s, Max Tilt 

Angle: 35°, Max Ascent Speed: 5 m/s, Max Descent Speed: 4 m/s, Max Speed: 22 m/s, Max 

Flight Altitude: 4500 m, Max Wind Speed Resistance: 10 m/s, Max Flight Time: Approximately 

18 minutes, Motor Model: DJI 3510, Propeller Model: DJI 1345, Operating Temperature Range: 

-10° to 40° C, Diagonal Distance: 559 to 581 mm, Dimensions: 438x451x301 mm (see attached 

manual)

The Phantom 3’s specifications are as follows:

Weight: 1280 g, Hovering Accuracy (GPS Mode): Vertical +/- 0.5m and Horizontal +/- 1.5m, 

Max Speed: 16 m/s, Max Flight Altitude above Sea Level: 6000 m, Max Flight Time: 

Approximately 23 minutes, Motor Model: DJI 3510, Propeller Model: DJI 1345, Operating 
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Temperature Range: -10° to 40° C, Diagonal Distance Including Propellers: 590 mm (see 

attached manual)

The Inspire 1 has a weight of about 6.47lbs, the Phantom 3 has a weight of 1280 g. 

This is well below the maximum FAA requirement of 55lbs. The maximum speed that I, 

Scott Cooper, use on the Inspire 1, Phantom 3 35 Knots. According to Overview of 

Small UAS Notice of Proposed Rulemaking, it states that a small UAS should not exceed 

87 knots.

I, Scott Cooper, pilot my UASs through remote control only by line of sight, and have 

live video feed for a secondary pilot to monitor video recording. I receive a live 

telemetry feed from my UASs during all flights which include remaining battery voltage, 

distance, altitude, and any abnormalities that may occur during flight. 

IV. Qualifications 

Remote UASs can be controlled by unmonitored amateur hobbyists with no safety plan 

or controls in place to help prevent catastrophe. I, Scott Cooper, have many years of 

experience in flying UAS, and can put a mind at ease knowing I have personally 

installed safety controls to avoid and prevent public hazard. 

I, Scott Cooper, have operated UASs for 3 years. During this experience, I have 

learned the standard safety protocols required before and during flight. 

For about a year, I, Scott Cooper have been as a hobby testing the capability of the 

UAS’s. My focus was on Capturing Virtual Data Quickly, Improving Data Collection 

Safety, Reducing Risk related to Bridge Infrastructures, Two way Radio Tower

Communication Towers & Two way Radio New Service planning. This entailed me to 

prove the use of UAS could replace and human data collection functions safely and in a 

fraction of the time. Because of this experience, I have learned how to program an 

UAS with safety controls, as well as other programming for functionality specific to the 

areas of interest for commercial benefit.

V. Intended UAS Operation

I, Scott Cooper’s intended UAS operations would be for the development of community, 

for real estate/realtor purposes, Search and Rescue, agricultural field monitoring, 

land/trusts inspections, structure inspections, and film/video productions, Cell Tower/ 

Two-way Radio Towers residing on Mountain Tops and provide a recordable safety 

inspection service to Commercial Operators of those services. My UAS operations 

would not affect safety, because I would fly within tightly controlled, predetermined 
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areas away from the general public, airports, and vehicular traffic. I would fly in wide 

open areas that are permissible property boundaries according to the local laws and 

regulations, FAA, and my clients. 

In addition to my intention of flying the Inspire 1, Phantom 3 safely according to the 

FAA rules, all of them were engineered to be as safe as possible for the PIC and its 

surroundings. The Inspire 1, Phantom 3 have built in flight control system and was 

made to be as safe as possible. The DJI Inspire 1 and Phantom 3 have an advanced 

“ready to fly” design, and have “safety features, including Return Home and position 

stabilization.”

VI. Operate Within Regulations

I, Scott Cooper will fly only within line of sight. The maximum altitude I will fly my UAS 

is 200 feet (well within the 400 ft regulated by the FAA Modernization and Reform Act 

of 2012). I will not fly behind obstacles or at distances that make it impossible to see 

my platform. The maximum operating speed I will operate is 35knots.

I, Scott Cooper, will not operate my UAS near airports, hospitals or police heliports, and 

near areas where general public is within fifty to one hundred yards. 

The Inspire 1, Phantom 3 are programmed for flight restriction in/within 5miles of any 

airports. According to the DJI website, when describing the Inspire 1 and Phantom 3 it 

states, “In order to increase flight safety and prevent accidental flights in restricted 

areas, DJI has introduced a No Fly Zones feature to help everyone use their DJI 

products safely and legally.These zones 

include airports worldwide and other areas where flying might pose an unnecessary 

risk, including national borders and sensitive institutions.” A safety NO fly zone map 

database is being updated constantly and is available for UAS operators to check before 

flying the UAS. The link is: http://flysafe.dji.com/no-fly

I, Scott Cooper, am constantly on alert for any manned aircraft and prepared to 

land/abort immediately to the nearest and safest ground point should a manned aircraft 

approach, or I my location. 

My UAS is capable of vertical and horizontal operations, and is flown only within my line 

of sight. It has capabilities of geofencing which will prevent the craft from exceeding a 
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set altitude or distance. No matter what causes the craft to breach those boundariesthe craft is forced back within the boundary limits. It will take over the craft to keep it 

within those set boundary lines and allow the pilot to regain control once the craft is 

within those boundaries. My UAS is flown with a second operator who aids in watching 

for any obstacles. I, Scott Cooper, do not believe in taking risks that may cause a 

crash, that could create hazard to the public/property/aircrafts, and I have no desire to 

lose an investment. I have clocked numerous practice flights and simulated flights to 

gain familiarization with the characteristics of this specific UAS’s performance under 

different temperature and weather conditions. This helps me build adequate skills and 

response reflex time for safety. 

I, Scott Cooper, will only operate in safe environments that are strictly controlled. The 

environment will be safely away from power lines, elevated lights, airports, and actively 

populated areas. I conduct extensive preflight inspections and protocols. I always will 

have all necessary permissions prior to operation, and have procedures in place to abort 

flights in the event of safety breaches or potential danger. 

VII. Exemption from Regulations

The FAA May Publish in the Federal Register:

14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and the like. 

14 C.F.R.21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR 91.203 (a) (1). 

The size, weight, and operational area of my, Scott Cooper, UAS, permits exemption 

from Part 21, because my UAS meets (and exceeds) and equivalent level of safety 

pursuant to Section 333 of the Reform Act. Both pieces of legislation permit the FAA to 

exempt UAS’s from the airworthiness certificate requirement in consideration of the 

weight, size, speed, maneuverability, and proximity to areas such as airports and dense 

populations. My, Scott Cooper’s, current and projected UAS’s meet or exceed each of 

the elements. 

14 C.F.R. 91.7 (a) Prohibits the operation of an aircraft without an airworthiness 

certificate. This regulation is inapplicable, because no such certificate will be applicable 

in contemplated by the FARs.

14 C.F.R. 91.9 (b) (2) Requires an aircraft flight manual in the aircraft. As there are no 

on board pilots or passengers, and given the size of the UAS’s, this Regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining a 

safety/flight manual delineating areas of where safety can be defined.
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The FAA has previously issued exemption to this regulation in Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700, and 32827.

14 C.F.R. 91.121 Regarding altimeter settings is inapplicable as my UAS utilizes 

electronic global positioning systems with a barometric sensor or controlled GPS 

“geofencing.”

14 C.F.R. 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The same 

level of safety will be achieved by maintaining any such required certifications and 

registrations by me, Scott Cooper.

B. 14 C.F.R. 45.23: Marketing of the Aircraft. Applicable Codes of Federal Regulation 

require aircraft to be marked according to certain specifications. My UAS can be 

marked with the appropriate “N” number once this “N” number has been given.

C. 14 C.F.R. 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. 

61.113 (a) & (b), private pilots are limited to non-commercial operations. I, Scott 

Cooper, can have equivalent level of safety as achieved by current Regulations, because 

my UAS does not carry any pilots or passengers. A pilot license will not ensure remote 

control piloting skills. The risks attended to the operation of my UAS are far less than

the risk levels in the commercial activities outlined in 14 C.F.R. 61. Thus, allowing me, 

Scott Cooper, to operate my UAS to meet and exceed current safety levels in relation to 

14 C.F.R. 61.113 (a) & (b).

D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. 91.119 prescribes safe altitudes 

for the operation of civil aircraft. My UAS will never operate at an altitude greater 200 

above ground level; safely below the standard of 400 AGL. I, Scott Cooper, will 

however operate my UAS in safe areas away from public and traffic in minimum safe 

altitudes. 

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417 (a) & (b): Maintenance 

Inspections. These Regulations only apply to aircraft with an airworthiness certificate. 

They will not, therefore, apply to my, Scott Cooper’s, UAS. However, as a safety 

precaution, I inspect my UAS before and after each flight.

In summary, I, Scott Cooper, wish to receive exemption from the following Regulations: 

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113 (a) &(b); 14 C.F.R. 91.7 

(a); 14 C.F.R. 91.9 (b) (2); 14 C.F.R. 91.103(b); 14 C.F.R. 91.109; 14 C.F.R. 91.119; 14 

C.F.R. 91.121; 14 C.F.R. 91.151 (a); 14 C.F.R. 91.203 (a) and (b); 14 C.F.R. 91.405 (a); 
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14 C.F.R. 91.407 (a)(1); 14 C.F.R. 91.409 (a) (2); and 14 C.F.R. 91.417 (a) & (b) to 

commercially operate my, Scott Cooper, small UASs in community awareness, structural 

inspection, search and rescue, and real estate , Cell Tower, Two-Way Radio Tower 

Safety Inspection ( Mountain Tops ) documentation to provide future services for 

operations within the Arizona State. 

I will use safety protocols and the implementation of a flight operations manual for the 

means and methods for safe flight. I, Scott Cooper, respectively request that the FAA 

grant my exemption request, and Iam willing to cooperate in sharing information with 

the FAA for the safety of the public.

Sincerely,

Scott Cooper

10265 W Patrick Lane

Peoria, Arizona 85383

Realtime-Flight@centurylink.net