### 2001 Airway Ave.

Fort Collins, Colorado 80524

larry.hansen@paravion.com

970

- 484

- 6804

October 2 6 , 2015

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

Reference: Exemption request under the provisions of Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations.

Dear Madam or Sir:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 an d 14 CFR Part 11,

I N. Larry Hansen, President of Century Helicopters Inc. seek an exemption from Federal Aviation Regulations listed herein for the operation of DJI Phantom and Inspire Series and Parrot Bebop series UAS s

. Due to manufacturers continuing model number changing, it is in

the best interest of the FAA and our company to apply for this exemption by referring to a “series” rather than a specific model number. This reduces the necessity to continually reapply

fo r an exemption due to a simple model change of the UAS although we are aware of the necessity to register with the FAA each UAS prior to commercial operations

. Currently the DJI Phantom is at model 3 and the DJI Inspire is at model 1. The Parrot is prese ntly the model name Bebop. Please refer to the attached specifications.

This request for exemption is in support of an application for a C ommercial Certificate of

Authorization to us e the above listed UAS s in various operations within the US to include aerial photography, aerial survey, patrolling and aerial inspection, search and rescue, forest and wildlife management, agriculture monitoring, livestock management, mapping, and real estate video imaging. An approval of this exemption by the F AA will provide a reduction in environmental and public impact thr o ugh the use of small UAS equipment in place of large rotorcraft and airplanes commonly us ed to accomplish the same tasks. As a result, the reduction in the impact of these activities is in th e best interest of the public

.

Each of the DJI and Parrot UAS weigh far less than the maximum 55 pounds allowed by current regulation. Also, the maximum speed capability is less than 35 miles per hour. The DJI and

Parrot series UAS s are very small

, popula r quadcopters equipped with high resolution videoimagery systems , making them the ideal airborne platform for many projects requiring detail ed viewing of objects and terrain without inducing undo harm to persons or property on the ground.

Unlike con v en tional manned aircraft, their noise footprint is almost undetectable when flown at

reasonable altitudes and distances from sensitive areas.

Century Helicopters, Inc. requests to be exempt from the following Title 14 CFR Regulations due to the lack of appl icability to small UAS s and their operations . Each regulation has previously , many times over, been approved as exempt for Small UAS operations (supporting data) and therefore further deliberation is kept to a minimum

.

14 CFR 21(h)

14 CFR 45.23

14 CFR 61.113 14 CFR 91.9(b)(2) 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) 14 CFR 91.417(a) and (b)

14 CFR 21 Subpart H

— Airworthiness Certificates

Due to the size and nature of these UASs, we feel the necessity to pursue a Type Certificate is beyond the scope of this regulation.

45.23 Display of marks; general

Due to the small size of these UAS s , it may not be possible to maintain the 2” minimum height

for required markings. Therefore, the markings shall be as large as space allows.

61.113 Private pilot privileges and limitations: Pilot in command Due to the UASs being unable to carry persons or property, the pilots need not be commercially

rat ed to conduct our planned operations.

91.9 Civil aircraft flight manual, marking, and placard requirements Due to the size and limited payload capability, it would be impractical to transport a POH or
other documentation on board the UAS. Therefore, these items shall be maintained at the base

station.

91.119 Minimum safe altitudes: General Since UAS operations are limited to a maximum of 400 feet AGL, the intent of this regulation does not apply.

91.121 Altimeter settings These UAS’s are not equipped with a barometric altimeter. The altitude is reported through the

means of GPS or other electronic devices located on the UAS. There are no means to adjust or

calibrate these devices.91.151 Fuel requirements for flight in VFR conditions

These UAS s do not require fuel as they operate on battery power. They only have an endurance of 15 to 25 minutes. Each is equipped wit h a battery level indication and a low battery warning system visible by the pilot on the base station display . Due to the limited

endurance of these craft , this regulation in not applicable.

91.203 Civil aircraft: Certifications required

Due to the si ze and nature of these UASs, we feel the necessity to pursue a Type Certificate is beyond the scope of this regulation. A registration certificate shall be maintained at the base

station.

91.405 Maintenance required

- thru 91.417 Maintenance records Due to the small size and nature of the UAS, the scope of these regulations is far broader th a n

necessary to operate these craft in a safe manner. The UASs shall be maintained in

accordance with each manufacturer’s recommendations. All maintenance activities shall be recorded and the record shall be kept at the base station.

All commercial operations will be conducted under day VFR conditions in accordance with current FAA regulations by a US FAA licensed pilot with the necessary training to safely accomplish the assigned task. A commercially rated pilot is not required as no persons or
property a re being transported. Preparation for each flight will include a preflight inspection of the UAS as recommended by the UAS manufacturer and a review of th e current status of the weather and airspace in which the UAS is to be operated. An APP such as ForeFlight or other similar product will be installed on each viewing device used to operate the UAS. This APP will provide information on airspace restrictio ns such as airspace class, TFRs, airports, congested airspace, and restricted airspace. It will also provide current and forecasted weather and other essential information necessary to conduct a safe flight.

Each UAS to be covered under this exemption is equipped with several safety devices to help prevent uncontrolled flight that may create an unsafe situation. Such items a re low battery warning system s , return to home capability, auto takeoff and landing capability, and restrictive

altitude and locatio n systems all of which provide a degree of safety unmatched by current

manned aircraft.

Best Regards,

N. Larry Hansen

President Century Helicopters, Inc.DJI Phantom 3DJI Inspire 1Parrot Bebop