UAV Look, LLC 2015 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 Modernization 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 commercial operation of its Small Unmanned Aircraft Systems for aerial photography, 

video, inspections, surveying, scientific documentation, and search and rescue so long as such 

operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333.

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

controlled conditions in airspace that is limited, predetermined and controlled. UAV Look seeks

to use sUAS for commercial purposes to include (but not be limited to) photography,

videography, marketing/advertising, inspections and scientific data gathering. It would provide 

safety enhancements 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 the Secretary of Transportation’s duty to “establish requirements 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.com
UAV Look, LLC 2015 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 Act grants the FAA authority to issue exemptions. This legal authority 

includes exempting civil aircraft, as the term is defined under §40101 of the act, including small 

unmanned aircraft systems, from the requirement that all civil aircraft must have a current

airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any sections 44702-44716 of this title if the

Administrator finds the exemption in the public 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 Secretary in 

determining whether small unmanned aircraft systems may operate in 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 establish 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 

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

vertically and horizontally at the same time. The small unmanned aircraft systems will only be 

operated within the Pilot’s visual line of sight at all times and will operate under the guidelines 

of the Pre-Flight Checklist attached as Exhibit 1. Operating in such a way will ensure that the 

small unmanned aircraft systems will “not create a hazard to users of the national airspace 

system or the public.” FAA Modernization and Reform Act of 2012 Section 333 (b).
UAV Look, LLC 2015 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, allow 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 restricted 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 

authority 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 interest. 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 required 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 small 

unmanned aircraft systems on a project site can significantly reduce the risk to workers because 

they can collect visual 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 cost, 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 replace 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 five 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 from helicopters presents a notable increase in safety for the public.

Lastly, small 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 fossil fuels 

burned in operation of small aircraft that are much heavier.
UAV Look, LLC 2015 4

III. Equivalent Level of Safety

UAV Look proposes that 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 equivalent 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 will be conducted within visual line of sight of the pilot.

3. Flight time for each operational flight will be no more than 30 minutes. The UAS is 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 who 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 area.

9. A brief "Pre-Flight Plan" will be conducted 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 trained 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 satellite 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 the 

aircraft to have (1) completed a sUAS flight training course.

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

controlled 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 2015 5

The UAS to be operated is less than 55 lbs. fully loaded, carries neither a pilot 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 operator 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 flight. 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 Preflight 

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 controls 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 the 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 2015 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 flight 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 flight 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 GPS 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 the sUAS provides approximately 30 minutes of powered flight. To meet 

the 30 minute 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 time 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 

compliance 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 an 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 operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 

10673, and 10808.
UAV Look, LLC 2015 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 certificate 

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 operated 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, 9789A, 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 and 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 2015 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 monitoring and surveying creates a greater risk because the craft 

are much larger, have combustible fuel, and carry an onboard human pilot. In contrast, a sUAS 

weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given 

the reduced 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 small UASs, weighing less than55 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 proximity 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 environment and operation within 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, LLC
UAV Look, LLC 2015 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 1.4
UAV Look, LLC 2015 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