North Coast Flight School inc. Gregory S. Hayes 1605 Asbury Rd. Erie, Pa. 16505 February 9, 2015

U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington DC 20590

Re: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 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); 14CFR 91.417(a) and (b)

Dear Sir or Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 CFR Part 11, North Coast Flight School Inc./ Gregory S. Hayes, operatorofan Unmanned Aircraft System (UASL hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofits UAS, so long as such operations are conducted within and underthe conditions outlined herein oras may be established bythe FAA as required by Section 333. Commercial operation ofan UAS, as described herein, which are equipped with camera(s) and sensors, would operate in thefollowing manner: 1. The abilityto offertrainingto persons individually or belonging to both private and/or public organizations that have interests in the use and application ofa UAS forthe purpose ofthe safe operation ofa UAS to enhance the safety ofthe National Airspace System (NAS) as well as for the protection ofthe persons and property 2. Aerial video/photography or providing livevideo feed to assist with search and rescue operations in cases ofan emergency or natural disaster only when the local authorities or government has requested it by contract or donation. 3. Aerial photography and/orvideo for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities. 4. Aerial video and/or photographyfor public and/or private use includingtelevision, public events, cinematography and news gathering. 5. Aerial inspection/photography ofresidential/commercial utility infrastructure including but not limitedto electrical power lines, wind turbines and cell towers.U.S. Department ofTransportation February 9, 2015 Page 2

As described fully below, the requested exemption would permitthe operation ofa UAS undercontrolled conditions in the NAS thatwould 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 ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to "

....establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system." The name and address ofthe applicant is: North Coast Flight School inc. Attn: Gregory S. Hayes, Director ofOperations/Owner Ph: 814-434-0875 Email: gshncfs@yahoo.com Address: 1605 Asbury Rd. Erie, Pa. 16505 Regulations from which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 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)

North Coast Flight School inc. will operate



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### ~hd rnbvealong/a vertical and hbritbntafplane simultaneously. The.DJI Inspire 1 has four motors, Motor ModeiDJI3510, poweredby a6-cell 4500mAh or'5700mAh Lithium Polymer battery. There are four propellers, Propeller Model DJI 1345, in use. The DJI Inspire 1 will be controlled with the C1 remote controllerwith an.operatingfrequency of2.400GHz- 2.483GHz. The live video feed will have an operatingfrequencyof5.728GHz- 5,850GHz. The applicantwill operate the UAS in line ofsight within a closed offand predetermined area owned and/operated by the property representative.U.S. Department ofTransportation February 9, 2015 Page 3

Given the small size ofthe UAS and the controlled environment provided the proposed operations will adhere to the Reform 

### Act's safety requirements. The approval ofthis application presents no national security issues. Regarding the level ofsafety surroundingthe proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant ofthe requested exemption is in the public interest. Accordingly the applicant requests thatthe FAA grantthe requested exemption with minimum delay. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The operation limitations proposed for an equivalent or higher level ofsafety because operations will further enhance the safety ofthe persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere towhen conducting commercial operations underthe FAA issued exemption as set forth in the Flight Operations Manual (FOM) include: 

### 1. The UAS will weigh less than 55 lbs. 2. The UAS will have a maximum operating speed of no more than 50mph. 3. Flights will be operated within line ofsight ofthe Pilot in Command (PIC) and/orVisual Observer (VO). 4. Maximum flight timefor each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve or30 minutes offlight time whichever occurs first. 5. Flights will be operated at an altitude of no morethan 400 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned. 6. Minimum crew for each operation will consist ofthe UAS Pilot, the Visual Observer {VO) and may include but not limited to a Camera Operator. 7. The UAS pilot will be adesignated Pilot in Command (PIC) will hold aCommercial Pilot's License along with a Second or higher Class Medical Certificate. Ifthe PIC feels another operatorto be qualified with the necessary skills to be PIC & possess a Commercial Pilot's License along with a Second or higher Class Medical Certificate, that person may be designated PIC provided they have a minimum of20 hours offlight time with the UAS. 8. A briefingwill be performed regarding the planned UAS operations priorto each day's flight consisting ofall the days' production activities. 9. All flights will occur underVisual Flight Rules Meteorological Conditions (VMC) only. 10. The flights will occur no closerthan a 5 mile radius ofthe geographic center/Airport Reference Point (ARP) ofatower controlled or uncontrolled airport or underthe guidance ofthe local FAA. 11. Ifoperations will be within a 5 mile radius ofthe geographic center/Airport Reference Point (ARP) of atower controlled or uncontrolled airportthe respective airports will be contacted advising them of the estimated flight time, flight duration, elevation offlight and other pertinent information. 12. The operatorwill file FAA Form 7711-1, or its equivalent, as modified in light ofthe requested exemption, with the appropriate local Flight Standards District Office (FSDO) no morethan 72 hours but no less than 48 hours from planned operation. 13. The operatorwill obtain verbal/written consent ofall persons involved with the planned operation and ensure that only consenting persons will be allowed within 100feet oftheflight operation, and the radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, asU.S. Department ofTransportation February 9, 2015 Page 4

required underthe FOM. Withthe advanced permission ofthe FSDO, operations at closer range may be approved. 14. The PIC and VO will have been trained in operation of UAS and receive up-to-date information for the particular UAS to be operated. 15. The PIC and VO will be able to communicate by voice, radio, and/ortext at all times. 16. Written and/orverbal permission and permitswill be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate governmental agencies. 17. Ifthe UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capabilityto return to a pre-determined location within adesignated location and land autonomously. 18. The UAS will have the capability to abort aflight 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 forthe issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraftto be utilized by theApplicant, an exemption from Part 21 Subpart Hmeets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorizethe FAA to exempt aircraftfrom the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates thatthe UAS operated without an airworthiness certificate, in the restricted environment and underthe conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operatingwith an airworthiness certificate withoutthe restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neithera pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within asecured and designated area. Unlike other civil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operator and underthe requirements and in compliance with local public safety requirements. The FAA will have advance notice ofall operations. These safety enhancements provide a greater degree ofsafetyto the public and propertyowners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstratesthat there is no credible threatto national security posed by the UAS, due to its size, speed of operation, location ofoperation, lack ofexplosive materials orflammable liquid fuels, and inabilityto carry a substantial external load. 14 C.F.R. §45.23 (b). Marking ofthe Aircraft The regulation requires: When marks include onlythe 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 operatorU.S. Department ofTransportation February 9, 2015 Page 5

must also display on that aircraft near each entranceto 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 UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilotstation on which the word "Experimental" can be placed. Given the size ofthe UAS, two-inch letteringwill be impossible. The word "Experimental" will be placed on thefuselage in compliance with §45.29 (f). The equivalent level ofsafety will be provided by havingthe UAS marked on its fuselage as required by §45.29 (f) wherethe pilot, observer and others workingwith the UAS will see the identification ofthe UAS as "Experimental." 14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command. Pursuant to 14 CFR 61.113 (a) & {b), no person who holds a private pilot certificate may act as a pilot in command ofan aircraftthat is carrying passengers or propertyfor compensation or hire. North Coast Flight School inc./Gregory S. Hayes may achieve an equivalent level ofsafety as achieved by current Regulations because the applicant's UAS do not carry any pilots or passengers nor property. The risks attendantto the operation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The PIC ofthe UAS will have Commercial Pilot's License along with a current Second Class or higher Medical exceedingthe current safety levels in relation to 14 CFR 61.113 (a) & (b). Ifeel the operation and limitations set forth in the FOM will equate to the safe operation ofthe 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 forthe aircraft, should this exemption be granted, no FAA regulatorystandard will exist for determining airworthiness. Given the size ofthe aircraft for maintenance and use ofsafety check lists priorto each flight an equivalent level ofsafetywill 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 ofthis 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 UAS, given its size and configuration has no abilityor place to carry such aflight 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 ofsafety will be maintained by keeping theflight manual at the ground control pointwhere the pilotflyingthe UAS will have immediate access to it.U.S. Department ofTransportation February 9, 2015 Page 6

14 C.F.R. § 91.103: PreflightAction. This regulation requires each pilot in command totake certain actions beforeflight to insure the safety of flight. As FAA approved rotorcraftflight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures including but not limitedto reviewingweather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation offlight. 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. UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use ofacontrol boxthat communicates with the aircraft via radio communications. The FAA has approved exemptions for flighttrainingwithoutfully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. The equivalent level ofsafety provided by thefact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed ofthe aircraft. 14 C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudesfor operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operatingthe helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authorityto operate at altitudes up to 400 AGL, or not morethan 200 above an elevated platform from which filming is planned, an exemption may be needed to allowsuch operations. As set forth herein, the UAS will never operate at higherthan 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph astructure whose height exceeds 400 feet AGL, the UAS will not be operated morethan 200 feet above the highest point on the structure. Itwill however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operationswithouttheir pre-obtained consent. The equivalent level ofsafety will be achieved given the size, weight, speed ofthe UAS as well as the location where it is operated. No flight will be taken withoutthe permission ofthe propertyowner or local officials. Because ofthe advance notice tothe property owner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operationswith aircraft or rotorcraft weightingfar morethan the maximum 55lbs. proposed herein and the lack offlammable 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 ofthe UAS will ensure separation between these UAS operations and the operations ofconventional aircraftthat must comply with Section 91.119.U.S. Department ofTransportation February 9, 2015 Page 7

14 C.F.R. §91.121 Altimeter Settings. This regulation requires each person operating an aircraftto maintain cruising altitude by reference to an altimeterthat is set "

...to the elevation ofthe departureairport or an appropriate altimeter setting available before departure." As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level ofsafetywill be achieved by the operator, pursuantto the safety check list and live flight data monitoring, confirmingthe altitude ofthe launch site shown on the GPS altitude indicator beforeflight. 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 underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel toflytothefirst point of intended landing, and, assuming normal cruising speed- (1) Duringthe day, to fly afterthatfor at least 30 minutes; or (2) At night, tofly afterthatfor at least 45 minutes." The battery poweringthe UAS provides approximately 30 minutes of powered flight. To meetthe 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UAS's proposed flight area and the location ofits proposed operations within a predetermined area, a longertimeframe for flight in daylight ortwilightVFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope ofprior exemptions. Operatingthe UAS, in atightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engenderthetype of risks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, limiting UAS flights to 10 minuteswould greatly reduce the utilityfor which the exemption will be granted. Applicant believes that an equivalent level ofsafety can be achieved by limiting flights to 30 minutes or 25% ofbattery power- whichever happens first. This restriction would be more than adequateto return the 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 itthefollowing: (1) An appropriate and current airworthiness certificate

.... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or aspecial flight authorization issued under §91.715 is displayed atthe cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs no morethan 55 lbs. and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents orto display them on the UAS.U.S. Department ofTransportation February 9, 2015 Page 8

An equivalent level ofsafetywill be achieved by keepingthese documents atthe ground control pointwhere the pilotflyingthe UAS will have immediate access tothem, to the extentthey are applicable tothe UAS. 14C.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 Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter

...," and others shall inspect or maintain the aircraft in compliance with Part 43. Given thatthese section and Part 43 apply onlyto aircraftwith an airworthiness certificate, these sections will not apply tothe applicant. Maintenance will be accomplished bythe operator pursuanttothe flight manual and operating handbook. An equivalent level ofsafety will be achieved because the UAS is very limited in size and will carry asmall payload and operate only in restricted areas for a limited period oftime. Ifmechanical issues arise the UAS can land immediatelyand will be operatingfrom no higherthan 400 feet AGL. The operatorwill ensure thatthe UAS is in working order priorto initiatingflight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person most familiarwith the aircraft and best suited to maintain the aircraft in an airworthy condition to providethe equivalent level ofsafety. An equivalent level ofsafetywill be achieved because maintenance and inspectionswill be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operatorwill ensure that the UAS is in working order priorto initiatingflight and perform required maintenance needed. Additional Information The applicant, North Coast Flight School inc./Gregory S. Hayes, has been involved in the flight training business over 10years. Mr. Hayes is also the current Chairman ofthe Board of "The Flight School Association of North America {FSANA). His true desire is to educate the public as to the safe practices involved in the operation of UAS. Satisfaction ofcriteria provided in Section 333 ofthe Reform Act of2012 provide more than adequate justification for the grant ofthe requested exemptions allowingthe commercial operation ofthe applicant's UAS. Sincerely,

Gregory S. Hayes NCFS / FSANA