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Scott Cooper , Section 333 Exemption Petition 31 July, 2015 10265 W. Patrick Lane Peoria , AZ 85 383 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 system s (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. W ith 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, agri cultural field monitoring, land/trusts inspections, structure inspections, film/video productions , Cell Tower / Two way Radio Safety Inspections / Bridge or Infrastructure Safety Inspections

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I. Saf

ety, Design , and Operations The DJI I nspire 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 platform s . The advanced flight controller makes the In spire 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 4500mAh2

In telligent 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 us age 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 ) wh en 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 a ircraft 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 co ntrol over the UAS are slimmer; t hus, making the UASs a safer UAS then most. The small UAS s 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 C ell Tower / Two3

way Radio Mountain top inspection teams. My light weight UAS s 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 li mit 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 Inspire 1 , 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 I nspire 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): Vertical

0.5m 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: Approxima tely 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: 128 0 g, Hovering Accuracy (GPS Mode): Vertical +/

- 0.5m and Horizontal +/

- 1.5m, Max Speed: 16 m/s, Max Flight Altitude a bove Sea Level: 60 00 m, M ax Flight Time: Approximately 23 minutes, Motor Model: DJI 3510, Propeller Model: DJI 1345, Operating4

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 UAS s through remote contro l 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 UAS s 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 UAS s 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 I nfrastructures, 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 fi lm/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 ope rations would not affect safety, because I would fly within tightly controlled, predetermined5

areas away from t he general public, airports, and vehicular traffic. I would fly in wide open areas that are permissible property boundaries according to the l ocal 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 advance d “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. Th e 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 an y 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 i s 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 a6

set altitude or distance. No matter what causes the craft to breach those boundaries

the 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 env ironment 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 certi fi cates in relation to FAR 91.203 (a) (1). The size, weight, and operational area of my, Scott Cooper, UAS , permits exemption from Part 21, becaus e 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, ma neuverability, 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) P rohibits the operation of an aircraft without an airworthiness certifi cate. 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.7

The FAA has previously issued exemption to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565 B, 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 ce rtifications 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” numb er 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 fro m public and traffic in minimum safe altitudes. E. 14 C.F.R. 91.405 (a); 407 (a) (1); 40 9 (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);8

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 UAS s 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 gra nt 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

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