UAV Look, LLC 2 0 1 5 1

Ethan Cohen, CEO UAV Look, LLC 8 Magnolia Street Newburyport, MA 01950

October 12, 2015

U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12

- 140 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Moder nization and Reform Act of 2012 and 14 C.F.R. Part
11, UAV Look, LLC is applying for an exemption from the listed Federal Aviation Regulations

to allow comm ercial operation of its Small Un manned Aircraft Systems for aerial photography, video, inspections, survey ing, scientific documentation

, and search and rescue so long as such

oper ations are conducted within and under the conditions outlined herein or as ma y be established by the FAA as required by Section 333.

The requested exemption wo uld permit the operation of small unmanned aircraft systems under

controlled c onditions in airspace that is limited , predeterm ined and controlled

. U A V L o o k s e e k s

t o u s e s U A S f

o r c o m m e r c i a l p u rp o s e s t o i n c l u d e ( b u t n o t b e l i m i t e d t o ) p h o t o g r a p h y
,

v i d e o g r a p h y
, m a r k e t i n g / a d v e r t i s i n g
, i n s p e c t i o n s a n d s c i e n t i f i c d a t a g a t h e r i n g

. It would provide safety e nhancements to the best practices safety protocols already established and followed by

UAV Look at all of our mission locations . Approval of this exemption would therefore enhance safety and fulfill th e Secretary of Transportation’s duty to “ establish requ irements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the FAA

Modernization and Reform Act of 2012

.

The name, address and contact information of the applicant is:

UAV Look, LLC

Attn: Ethan Cohen

8 Magnolia Street, Newburyport, MA 01950

Phone: 978

- 270

- 5399

Email: Ethan@Uavlook.comUAV Look, LLC 2 0 1 5 2

Regulations from which the exemption is requested:

14 C.F.R. Part 21 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) & (b) 14 C.F.R. 91.405 (a) 14 C.F.R. 407 (a) (1) 14 C.F.R. 409 (a) (2) 14 C.F.R. 417 (a) & (b)

I. Legal Authority for Exemptions

The Federal Aviation A ct grants the FAA authority to issue exemptions. This legal authority includes exempting civil aircraft, as the term is defined under §40101 of the a ct, including small unmanned aircraft systems , from the requirement that all civil aircraft must have a cur rent
airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this sect ion or any sections 44702

- 44716 of this title if the Administrator finds the exemption in the pu blic interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a) (1).

Section 333(b) of the FAA Modernization and Reform Act of 2012 assists the Secre tary in determining whether small unmanned aircraft systems may operate i n the National Airspace System without creating a hazard to the user, the public, or a threat to national security. If the Secretary determines that a small unmanned aircraft system “may operate safely in the national airspace system, the Secretary shall e stablish requirements for the safe operation of such aircraft in the national airspace system.” Id. §333(c). UAV Look’s small unmanned aircraft systems are multi

- rotor vehicles, weighing less than 55 lbs. including payload. They operate under normal

condit ions at a speed of no more than 50 knots and are capable of hovering and moving

vertical ly and horizontal ly at the same time

. The small unmanned aircraft systems will only be operated with in the Pilot’s visual line of sig ht at all times and will operate under the guidelines

of the Pre

- Flight Checklist attached as Exhibit 1. Operating in such a way will e nsure that t he small unmanned aircraft systems will “not create a hazard to users of the national airspace

s ystem or the public.” FAA Modernization and Re form Act of 2012 Section 333 (b).UAV Look, LLC 2 0 1 5 3

Due to the small size of the unmanned aircraft systems being used as well as the restricted and

controlled environment within which they will operate, our application falls squarely within the zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, all ow commercial operations of small unmanned aircraft systems to commence immediately. Additionally, due to the small size of these unmanned aircraft systems and the low

altitudes and re stricted areas in which the they will operate, approval of our application poses no threat to national security or other manned aircraft

.

Given the clear direction in Section 333 of the FAA Modernization and Reform Act of 2012 , the

au thority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, the grant of the requested exemptions is in the public inte rest. UAV Look, LLC respectfully requests that the FAA grant us this exemption.

II. Public Interest

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333( a) through (c) of the FAA Modernization and Reform Act of 2012 . This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the NAS before completion of the rule making r equired under Section 332 of said Reform Act. By granting an exemption the FAA will fulfill Congress’s intent of allowing UAS to operate with significant safety precautions in low risk environments. The use of s mall unmanned aircraft systems on a project site can significantly redu ce the risk to workers because they can collect v isual data on hard to reach areas that otherwise would require potentially dangerous in

- person inspection . Falls are a leading source of workplace fatality and injury on project sites, and reducing falls through the use of small unmanned aircraft systems for site imaging could save lives.

These small unmanned aircraft systems are also less costly to operate than traditional helicopters or small aircraft. Due to the reduced operating co st, aerial photos, video and documentation can now be used by a larger part of the public whereas before, the use of traditional aircraft was cost prohibitive to a vast majority of the public.

Additionally, these small unmanned aircraft systems could r eplace the use of helicopters and small aircraft to photograph and video locations for a host of purposes from real estate marketing

to scientific data collection

. The small unmanned aircraft systems we propose to fly in this application are under fifty fi ve pounds, and do not carry any combustible material on board, as opposed to the much larger conventionally powered small aircraft. Moving to small unmanned aircraft systems fr om helicopters presents a notable increase in safety for the public.

Lastly, s mall unmanned aircraft systems reduce the environmental impact of aerial

documentation by dramatically decreasing the energy used for imaging and data collection. Our small unmanned aircraft systems use rechargeable lithium ion batteries, as opposed to fos sil fuels burned in operation of small aircraft that are much heavier.UAV Look, LLC 2 0 1 5 4

III. Equivalent Level of Safety

UAV Look proposes tha t the exemption requested here apply to small unmanned aircraft systems

that possess the characteristics and that operate with the limitations listed herein. These limitations provide for at least an eq uivalent level or higher of safety to operations . UAV Look will be bound by the following limitations when conducting its small unmanned aircraft system operations under an FAA issued exemption:

1. The sUAS will weigh less than 55 pounds. 2. Flights w ill be conducted within visual line of sight of the pilot.

3. F light time for each operational flight will be no more than 30 minutes. The UAS i s able to

calculate battery reserve in real time, and will return to its ground station with at least 20% battery power reserve should that occur prior to the 30 minute limit. 4. Flights will normally be operated at an altitude of 200 feet AGL, never exceeding 400 feet

AGL. 5. Any flight within 5 miles of an airport will not be flown without the prior notification and approval of the local FAA Flight Standards District Office (FSDO) and airport controller.

6. Crew for each operation will consist of the UAS Pilot in Control wh o will keep the UAS

within his /her visual line of sight at all times.

7. The UAS Pilot will be trained in flight, operations, and safety procedures.

8. The UAS will only operate within the establishment of a “Security Perimeter” for the flight operations a rea. 9. A brief "Pre

- Flight Plan" will be cond ucted in regard to the planned UAS operations prior to each day’s production activities. 10. The property owner will consent to the UAS flyover on site by verbal or written consent.

11. Pilot will have been tra ined in operation of UASs generally and received up

- to

- date information on the particular UAS to be operated as required. 12. If the sUAS loses communications or loses its GPS signal, it will have capability to enter “loiter mode” and hover, reestablish sa tellite connection, and return to a pre

- determined location within the Security Perimeter and land.

IV. Description of Specific Regulations

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command

Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the small unmanned aircraft system will not carry a pilot or passengers, the proposed operations can

achieve the equivalent level of safety of current operations by requiring the Pilot operating th e aircraft to have (1) completed a sUAS flight training course.

Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely

co ntrolled with no living thing on board. UAS used by UAV Look also can be operated by an autopilot, which greatly reduces the danger of human error. The area of operation is controlled and all flights are planned and coordinated in advance.UAV Look, LLC 2 0 1 5 5

The UAS to be operated is less than 5 5 lbs. fully loaded, carries neither a pilo t nor passenger, carries no explosive materials or flammable liquid fuels, and operates within visual line of sight of a trained pilot in control . Like other civil aircraft, operations under this exemption will be tightly controlled and monitored by the op erator and in compliance with local public safety requirements, to provide security for the area of operation.

14 C.F.R. 91.103: Preflight Action

This regulation requires each pilot in command take certain actions before flight to ensure the safety of fli ght. An exemption is needed from this requirement as the Pilot will take separate preflight actions, including checking for weather conditions, checking flight battery requirements, checking takeoff and landing distances, and all other actions in the Prefl ight Checklist. These actions will provide an equivalent level of safety.

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.

sUASs and remotely piloted aircraft, by their design do not have fully functional dual controls.
Flight control is accomplished through the use of a control box that communicates with the
aircraft via radio communications. The FAA has approved exemptions for flight training without
fully functional dual control s for a number of aircraft and for flight instruction in experimental
aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety provided is
achieved by the fact that neither a pilot nor passengers will be carried in the aircraft and by the
size and speed of the aircraft.

14 C.F. R. 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119(d) allows helicopters to be operated at less than the minimums prescribed, provided t he person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 feet AGL, or not more than 200 feet above an elevated platform from which operation is planned, an exemption may be needed to allow such operations. As set forth herein the UAS will never operate at higher than 400 AGL. It will be operated in a restricted area with a security perimeter, where buildings and people will not be exposed to operations without their

pre

- obtained consent.UAV Look, LLC 2 0 1 5 6

The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the location where it is operated. No flig ht will be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner and participants in the mission, all affected individuals will be aware of the planned flight operations. Compared to flig ht operations with aircraft or rotorcraft weighing far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 feet AGL. In addition, the low

- altitude operations of the sUAS will ensure separation between these small UAS operations and the operations of conventional aircraft that must comply with Section

91.119.

14 C.F.R. 91.121: Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the Safety Check list, confirming the altitude of the

launch site shown on the GP S altitude indicator before flight.

14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions

Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. Our

sUAS is limited to operations in sterile and controlled environments, and has a limited range and flight time which require an exemption from 14 CFR 91.151(a).

The battery powering th e sUAS provides approximately 30 minutes of powered flight. To meet
the 30 m inute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 20 minutes in length. Given the limitations on the sUAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer tim e frame for flight in daylight or night VFR conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without

co mpliance with FAR 91.151 (a)). Operating the small UAS, in a tightly 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 engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally, limiting sUAS flights to 20 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes that a n equivalent level of safety can be achieved by limiting flights to 20 minutes or 25% of battery power whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operati ng area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.UAV Look, LLC 2 0 1 5 7

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 it the following:

(1) An appropriate and current airworthiness certificate. . . . (b) No person may operate a civil aircraft unless the airworthiness certific ate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to

passengers or crew.

The UAS fully loaded weighs no more than 55 lbs and is operate d without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665,
9789, 97 89A, 9797, 9797A, 9816A, and 10700.

14 CFR 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 E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to UAV Look. Maintenance will be accomplished by the operator by using the pre

- flight checklist and user manuals . An equivalent level of safety will be achieved because these small sUAS are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the sUAS can land immediately and will be operating from no higher than 400 feet AGL. The Pilot will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the Pilot is the person

most familiar with the aircraft a nd best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed:UAV Look, LLC 2 0 1 5 8

Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a);

91 .407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less).

Approval of exemptions allowing commercial operations of sUAS enhances safety while reducing risk. Manned aircraft monitori ng and surveying creates a greater risk because the craft are much larger, have combustible fuel, and carry an onboard human pilot. In contra st, a sUAS weighing fewer than 5 5 lbs. and powered by batteries eliminates virtually all of that risk given

the red uced mass and lack of combustible fuel carried on board. The sUAS will be carried to the worksite, not flown. It will carry no passengers or crew and, therefore, will not expose them to

the risks associated with manned aircraft flights.

The operation of s mall UAS s, weighing less than5 5 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close prox imity to the ground and people.

Privacy

All flights will occur over private or controlled access property with the property owner’s prior consent and knowledge. Images taken will be of individuals who have also consented to being

filmed or otherwise have agreed to be in the area where aerial photography will take place.

Conclusion

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

-- size, weight, speed, operating capabilities, controlled operating e nvironment and operation wit hin visual line of sight provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant’s small unmanned aircraft systems

.

Sincerely

, Ethan Cohen

Chief Executive Officer UAV Look, LLCUAV Look, LLC 2 0 1 5 9

Appendix 1

1.1

– DJI Phantom 2 Vision+

See attached flight manual : DJI Phantom 2 Vision+ User manual 1.8

1.2

- DJI Phantom 3 Professional

See attached flight manual:

DJI Phantom 3 Professional User Manual 1.4UAV Look, LLC 2 0 1 5 10

1.3

– DJI Inspire 1

See attached flight manual: DJI Inspire 1 User Manual 1.4

Appendix 2

Please see attached:

UAV Look , LLC sUAS Pre

- Flight Checklist and Pre

- flight Plan