May 15,2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Cooley Drone Services 

Small Unmanned Aerial Systems 

Aerial Photography and Videography 

Re: Petition of Edward Cooley, dba Cooley Drone Services, for Exemption to Section 333 of the FAA 

Modernization and Reform Act of 2012 

To Whom It May Concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 C.F.R. 

Part 11, Edward Cooley, dba Cooley Drone Services, ("Petitioner''), the operator of a small business to 

provide commercial aerial photography and videography, hereby applies for an exemption from Federal 

Aviation Regulations ("FARs") identified below, to allow commercial operation of small unmanned aerial 

systems ("sUAS"). 

The exemption is in accordance with protocols outlined in this petition for exemption, the sUAS 

manufacturer's operations and/or instructions manual ("User's Manual" & "Training Guide"), 

Petitioner's Operations and Training Manual, and any other requirements established by the FAA 

pursuant to Section 333 ofthe Reform Act. 

For your convenience, the petition is organized as follows: 

1. Petitioner's description 

2. Relevant statutory authority 

3. Qualifications for approval under Section 333 of the Reform Act 

4. Description of proposed operations 

5. Regulations from which exemption is requested 

6. Public interest 

7. Privacy 

8. Federal Register summary 

9. Conclusion 

Petitioner's Description 

Petitioner is the retired Vice President of Operations for Tampa International Airport and an instrumentrated private pilot with over 3,000 hours of flight time. Petitioner has been an aircraft owner for over 

thirty years and a pilot operating in the National Airspace System for over forty-four years. Petitioner is 

starting up a new aviation business offering aerial photography and videography with the use of sUAS. 

Specifically, Petitioner wishes to provide aerial photography for building inspections, real estate sales 

services, commercial photography and videography services, and sUAS flight demonstration 
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services. Consistent with the requirements of 14 C.F.R. § 11.81{a), Petitioner provides the following 

information in support for exemption: 

The name and address of the Petitioner is: 

Edward Cooley 

18921 Chaville Rd. 

Lutz, FL 33558 

813 948-7001 (Home) 

813 389-7647 (Cell) 

email: 

Relevant Statutory Authority 

This petition for exemption is submitted to fulfill Congress' goal in passing Section 333 (a) through (c) of 

the Reform Act. In the Reform Act, Congress directed the FAA "to safely accelerate the integration of 

civil unmanned aircraft systems in the national airspace system" and, under Section 333 of that law, 

directed the Secretary of Transportation ("FAA Administrator") to consider whether certain unmanned 

aircraft systems may operate in the National Airspace System ("NAS") before completion of the 

rulemaking required under Section 333 of the Reform Act. In making this determination, the Secretary 

is required to determine which types of sUAS's do not create a hazard to users of the NAS or the public 

or pose a threat to national security in light of the following: 

The sUAS's size, weight, speed and operational capability; operation of the sUAS in close proximity to 

airports and populated areas; and, operation of the sUAS's within visual line of sight of the operator. 

If the Secretary determines that such vehicles "may operate in the National Airspace System, the 

Secretary shall establish requirements for the safe operation of such aircraft in the National Airspace 

System". In addition, the FAA Administrator has general authority to grant exemptions from its safety 

regulations and minimum standards when the Administrator decides a requested exemption is in the 

public interest. See 49 U.S.C. § 44701(f), (authorizing the grant of exemptions from the requirement of 

regulations prescribed pursuant to Section 44701 (a) or (b) and Section 44702-44716. A party 

requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a 

whole, and (2) would not adversely affect safety (or how it would provide a level of safety at least equal 

to the existing rules). See 14 C.F.R. §11.81 FAA, Petition for Exemptions. 

Qualification for Approval Under Section 333 of the Reform Act 

The proposed operations in this petition for exemption qualify for expedited approval under Section 333 

of the Reform Act. Each of the statutory criteria and other potentially relevant factors are satisfied. 

The proposed operations would permit the use of small and relatively inexpensive sUAS under 

controlled conditions in airspace that is, (1) limited; {2) predetermined; {3) controlled as to access, and 

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{4} would provide an increased level of safety beyond that existing when fixed or rotary wing aircraft are 

used to accomplish the same purpose. 

Petitioner's sUAS are rotorcraft weighing less than 55 pounds including payload. They operate, under 

normal conditions, at a speed of no more than 87 knots and have the capability to hover, and move in 

the vertical and horizontal plane simultaneously. 

Petitioner's sUAS's will operate in line-of-sight and will operate only within a sterile area described in 

the enclosed Operations and Training Manual. Such operations will insure that the sUAS will"not create 

a hazard to users of the National Airspace System or the public." 

Given the small size of the sUAS's involved and the restricted sterile environment within which they will 

operate, this petition for exemption falls squarely within that zone of safety, i.e. an equivalent level of 

safety, in which Congress envisioned that the FAA must, by exemption, allow commercial operations of 

sUAS's to commence immediately. Also, due to the size ofthe sUAS's and the restricted areas in which 

the sUAS's will operate, approval of the application presents no national security issue. 

Considering the clear direction in Section 333 of the Reform Act, the authority contained in the Federal 

Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, and the 

significant public benefit, including enhanced safety, reduction in environmental impacts, including 

reduced emissions associated with allowing sUAS's for the proposed operations, the grant of the 

requested exemptions is also in the public interest. Accordingly, Petitioner respectfully requests that 

the FAA grant the requested exemption without delay. 

Description of Proposed Operations 

The attached Operations and Training Manual describes, in detail, the procedures for Petitioner's 

proposed sUAS operations. To assist the FAA in the safety assessment of Petitioner's proposed sUAS 

operations, below is a summary of operational limitations and conditions which will insure an equivalent 

or higher level of safety to operations conducted under current regulatory guidelines. 

The sUAS aircraft that are proposed to be utilized under this grant of exemption are the OJI Phantom 

Vision 2 Plus and the DJI Phantom 3. Detailed information on these aircraft is included in the 

attachments of this petition. 

1. The sUAS will weigh less than 55 pounds with payload. 

2. The sUAS will not operate at a speed greater than 87 knots {100 mph). 

3. Flights will operate within line-of-sight of the pilot and visual observer. 

4. Maximum total flight time for each operational flight will be 25 minutes. Flights will be 

terminated at 25% battery power reserve, should that occur prior to the 25 minute limit. 

5. Flight will be operated at an altitude of no more than 400 feet above ground level ("AGL"). 

6. Minimum crew for each operation will consist of a Pilot and a Visual Observer ("VO"). 

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The sUAS pilot will be the Pilot in Command ("PIC"). If a pilot certificate holder other than the sUAS Pilot 

is present and posses the necessary PIC qualifications, that person can be designated as PIC. 

A briefing will be conducted in regard to the planned sUAS operations prior to each day's activities. It 

will be mandatory that all personnel who will be performing duties within the boundaries of the safety 

perimeter be present for this briefing. 

PIC and VO will have been trained in the operation of sUAS generally and will have received up-to-date 

information on the particular sUAS to be operated, as required in the Operations and Training Manual. 

PIC and VO will at all times be able to communicate by voice. Written permission from the relevant 

property holders will be obtained. 

All required permissions and permits will be obtained from federal, state and local jurisdictions, 

including local law enforcement, fire or other appropriate governmental agencies. 

If the sUAS loses communications or loses its GPS signal, the sUAS is equipped with advanced safety 

features that will allow the sUAS to automatically return to a pre-determined location. 

The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies. 

Regulation From Which Exemption is Requested 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. By its terms, this 

statutory authority includes exempting civil aircraft, as the term is defined under§ 40101 of the Act, 

including sUAS's, from the safety regulations and minimum standards when the Administrator decides a 

requested exemption is in the public interest. See 49 U.S.C. § 44701(f) (authorizing the grant of 

exemptions from a requirement of regulations prescribed pursuant to Section 44701(a) or (b) and 

Sections 44702-44716). 

Petitioner seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61 and 91 

for purposes of conducting aerial photography and videography using sUAS. Listed below are (1) the 

specific sections of 14 C.F.R. for which exemption is sought; and (2) the operating procedures and 

safeguards that Petitioner has established which will ensure a level of safety equal to or better than the 

rules from which exemption is sought. 

A. 14 C.F.R. Part 21, Subpart H, Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1). 

This petition seeks an exemption from 14 C.F.R. Part 21, Subpart H, which establishes the 

procedural requirements for the issuance of airworthiness certificates as required by 14 C.F.R. § 

91.203(a)(1). Given the size and limited operating area associated with the sUAS's to be utilized 

by the Petitioner, an exemption from Part 21, Subpart H, meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the Reform Act. 

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The Federal Aviation Act (49 U.S.C. § 44701(f)) and Section 333 of the Reform Act both authorize 

the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability and proximity to airports and 

populated areas of the particular sUAS. 

In all cases, an analysis of these criteria demonstrates that the sUAS operated without an 

airworthiness certificate, in the restricted environment and under conditions proposed, will be 

at least as safe, or safer, than a conventional rotorcraft operating with an airworthiness 

certificate without the restrictions and conditions of the proposed sUAS operations. 

Equivalent Level of Safety 

The sUAS to be operated hereunder weighs less than 55 pounds fully loaded, carries neither a 

pilot nor passengers, carries no explosive materials or flammable liquid fuels and operate 

exclusively within a secure defined area. Unlike other civil aircraft, the proposed operations in 

this petition for exemption will be controlled and monitored by the Operator, pursuant to the 

Operations and Training Manual's requirements. 

These safety enhancements, which already apply to civil aircraft operated in connection with 

existing inspection operations, provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued under 14 

C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates that there is 

no credible threat to national security posed by the sUAS, due to its size, speed of operation, 

location of operation, lack of explosive materials or flammable liquid fuels and inability to carry 

a substantial external load. 

B. 14 C.F.R. Part 27: Airworthiness Standards: Normal Category Rotorcraft 

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certif ication of normal 

category rotorcraft. To the extent the Petitioner's sUAS would otherwise require certification 

under Part 27, as a rotorcraft, Pet itioner's argument for exemption from these airworthiness 

standards for the same reasons identified in the exemption request from 14 C.F.R. Part 21 

Subpart H would apply. 

C. Aircraft Marking and Identification Requirements: 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a). 

This petition seeks an exemption from the aircraft marking and identification requirements of 14 

C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a). 

14 C.F.R. § 91.9(c), Civil aircraft flight manual, marking and placard requirements, provides that: 

No person may operate a U.S. registered civil aircraft unless that aircraft is identified in 

accordance with Part 45 of this chapter. 

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14 C.F.R. § 45.23(b), Marking of the Aircraft, states: 

Small Unmanned Aerial Systems 

Aerial Photography and Videography 

When marks include only the 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 operator must also display on that aircraft near each entrance to the cabin, cockpit, 

or pilot station, in letters not less than two inches, nor more than six inches high, the words 

"Experimental", "Restricted", "Light-sport", "Limited", or "Provisional", as applicable. 

14 C.F.R. § 45.27(a), Rotorcraft, states: 

Each operator of a rotorcraft must display on the rotorcraft horizontally on both surfaces of the 

cabin, fuselage, boom, or tail, the marks required by §45.23. 

Exemption from § 45.23(b) is warranted because the sUAS has no entrance to the cabin, cockpit, 

or pilot station on which the word "Experimental" et al can be placed. Moreover, given the size 

of the sUAS, two-inch letters would be impossible. The word "Experimental" will be placed on 

the fuselage in compliance with § 45.29(f). 

Given the nature of the specific relief sought by this exemption request, Petitioner requires 

relief from the associated marking and identification requirements of§ 45.27(a) and § 91.9(c), 

which would require compliance with§ 45.23(b). 

Equivalent Level of Safety 

An equivalent level of safety for exemptions to the aircraft marking and identification 

requirements of§§ 91.9(c), 45.23(b) and 45.27(a), will be provided by having the sUAS marked 

on the fuselage as required by§ 45.29(f) where the pilot, observer and others working with the 

sUAS will see the identification of the sUAS as "Experimental". Additionally, Petitioner will 

ensure compliance with any requests of sUAS marking by the FAA. 

As examples, the FAA has issued the following exemptions to the aircraft marking requirements 

of§ 45.23{b): Exemption Nos. 10700, 8738, 10167 and 10167A. 

D. 14 C.F.R. § 61.113(a) and (b): Private Pilot Privileges and Limitations: Pilot in Command. 

This petition seeks exemption from the private pilot privileges and limitations of§ 61.113 (a) 

and (b), which states: 

Private Pilot Privileges and Limitations: Pilot in Command. 

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a 

private pilot certificate may act as pilot in command of an aircraft that is carrying passengers 

or property for compensation or hire, nor may that person, for compensation or hire, act as 

pilot in command of an aircraft. 
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Small Unmanned Aerial Systems 

Aerial Photography and Videography 

(b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in 

connection with any business or employment if: 

{1) The flight is only incidental to that business or employment, and 

{2) The aircraft does not carry passengers or property for compensation or hire. 

Section 61.113(a) limits private pilots to being in command of non-commercial flights. Section 

61.113(b)(1) provides an exception that allows a private pilot to command an aircraft without 

passengers or property, in connection with business or employment if "the flight is only 

incidental to that business or employment." This exception likely does not apply to the 

proposed operations under this petition for exemption, as the flights are not incidental to the 

proposed aerial photography and video but rather essential to it. Accordingly, this petition 

seeks an exemption to§ 61.113(a) commercial limitation and/or§ 61.113(b)(1) requirement 

that the flight be incidental to the business to benefit from the exception. 

Equivalent Level of Safety 

Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety to§ 61.113(a) and (b), by requiring the PIC operating the sUAS to have 

the training on operation of the sUAS as defined in the Operations and Training Manual for the 

sUAS. 

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

controlled with no living thing on board. Moreover, the area of operation is controlled and 

restricted, and all flights are planned and coordinated in advance. 

The risks associated with the operation of small, lightweight sUAS are diminished from the level 

of risk associated with commercial operations contemplated by Part 61 when drafted, that 

allowing the proposed operations in this petition for exemption by requiring the PIC operating 

the sUAS to have training on operation of the sUAS as defined in the Operations and Training 

Manual for the sUAS, and that the sUAS is remotely controlled with no living thing on board, 

exceeds the present level of safety achieved by 61.113 (a) and (b). 

E. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft. This petition seeks an 

exemption from the flight manual requirements of 14 C.F.R. § 91.9(b)(2), which states: 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 of this chapter, 

unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, 

approved manual materials, markings, and placards or any combination thereof. 

Given the size, configuration, and load capacity the sUAS has no ability to carry such a manual 

on the aircraft, not only because there is no pilot on board, but because there is simply no room 

or capacity to carry such an item on the aircraft. 
Equivalent Level of Safety 

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Small Unmanned Aerial Systems 

Aerial Photography and Videography 

The safety-related purpose of this manual requirement can be equally satisfied by maintaining 

the sUAS flight manual at the ground control point where the pilot flying the sUAS will have 

immediate access to it. Accordingly, Petitioner requests an exemption from the§ 91.9(b)(2) 

flight manual requirements, on the condition that the sUAS flight manual be available at the 

control point during each operation. 

As examples, the FAA has issued the following exemptions to this regulation: Exemption Nos. 

8607,8737,8738,9299,9299A,9565,9565B,10167, 10167A, 10602,32827,and10700. 

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

This Petition seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be 

in an airworthy condition to be operated. Since there will be no airworthiness certificate issued 

for the sUAS, should this exemption be granted, no FAA regulatory standard will exist for 

determining airworthiness. 

Equivalent Level of Safety 

Given the size ofthe sUAS and the requirements contained in the sUAS Operations and Training 

Manual for maintenance and use of safety checklists prior to each flight, an equivalent level of 

safety will be provided. 

As examples, the FAA has issued the following exemptions to this regulation: Exemption Nos. 

8607,8737,8738,9299,9299A,9565, 9565B, 10167, 10167A, 10602,32827, and10700. 

G. 14 C.F.R. § 91.103 Preflight Action 

This petition seeks an exemption from § 91.103, which requires a PIC to become familiar with 

specific information before flight, including information contained in the FAA approved Flight 

Manual on board the aircraft. Inasmuch as the FAA approved Flight Manual will not be provided 

for the sUAS, an exemption will be needed. 

Equivalent Level of Safety 

An equivalent level of safety will be provided by following the sUAS comprehensive preflight 

checklist. The PIC will take all actions, including reviewing weather, flight battery requirements, 

landing and takeoff distances, and aircraft performance data, before initiating the flight. 

H. 14 C.F.R. § 91.105 Flight Crewmembers at Stations. 

This Petition seeks an exemption from§ 91.105, which requires flight crewmembers to be at 

their stations during takeoffs and landings and while enroute with their seatbelts and/or 

shoulder harness fastened unless the absence is necessary to perform duties in connection with 

the operation of the aircraft, or in connection with physiological needs. Inasmuch as sUAS are 

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remotely piloted aircraft by their design, they do not have flight crewmembers on board, but 

instead flight control is accomplished through the use of a control box that communicates with 

the sUAS via radio communications, and exemption will be needed. 

Equivalent Level of Safety 

Given the size and operational characteristics of the sUAS and the fact that no flight 

crewmembers are aboard the aircraft an equivalent level of safety will be achieved by having 

the sUAS operated by the PIC from the control station on the ground in VLOS and under 

complete operational control at all times in a contained and predetermined area of operations. 

I. 14 C.F.R. § 91.109(a): Flight Instruction 

This petition seeks an exemption from 14 C.F.R. § 91.109(a), which provides that a 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. sUAS's and remotely piloted aircraft, by 

their design, do not have fully functional dual controls. Instead, flight control is accomplished 

through the use of a control box that communicates with the sUAS via radio communications. 

Equivalent Level of Safety 

Given the size and speed of the sUAS, an equivalent level of safe training can still be performed 

without dual controls because no pilot or passengers are on board the sUAS, and all persons will 

be a safe distance away should the sUAS experience any difficulties during flight instruction. 

The FAA has approved exemptions for flight training without fully functioning dual controls for a 

number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K 

and 9862A. 

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

This petition seeks an exemption from the minimum safe altitude requirements of 14 C.F.R. § 

91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may not 

operate. Section 91.119(c) states that, over other than congested areas, an altitude of 500 feet 

above the surface, except over open water or sparsely populated areas. In those cases, the 

aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. 

Section 91.119(d)(1) provides: A helicopter may be operated at less than the minimums 

prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter 

complies with any routes or altitudes specifically prescribed for helicopters by the FAA. 

The sUAS is prohibited from operating at an altitude above 400 feet AGL. In order to carry out 

its mission of commercial photography and videography, the sUAS must operate in safe 

proximity to participating persons and property, and will operate in an approved, 

predetermined, sterile area away from all non-participating persons and property all in 

accordance with the Operations and Training Manual. 
Equivalent Level of Service 

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Compared to flight operations with rotorcraft weighing far more than the maximum of 55 

pounds proposed herein, and the lack of flammable fuel, any risk associated with these 

operations is far less than those presently presented with conventional aircraft. An equivalent 

level of safety will be achieved given the size, weight, speed of the sUAS as well as the location 

where it will be operated. The sUAS will be operated in a restricted area, where buildings and 

people will not be exposed to operations without their pre-obtained consent. No flight will be 

taken without the permission ofthe property owner and/or local officials. Because of the 

advance notice to the property owner and participants, all affected individuals will be aware of 

the planned flight operations. Furthermore, by operating at such low altitudes, the sUAS will 

not interfere with other aircraft that are subject to the minimum safe altitude regulations. 

K. 14 C.F.R. § 91.121 Altimeter Settings 

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an 

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the 

elevation of the departure airport or barometric pressure. An exemption is required because 

the sUAS does not have a barometric altimeter, but rather a GPS altitude readout. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved by following the procedures set forth in the 

Operations and Training Manual. As prescribed in the Manual, the operator will confirm the 

altitude of the launch site shown on the GPS altitude indicator before flight. Moreover, the PIC 

will use the GPS altitude indicator to constantly monitor the sUAS elevation, thus insuring 

operation at safe altitudes. 

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions. 

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This petition seeks an exemption from 14 C.F.R. § 91.151(a), fuel requirements for flight in VFR 

conditions. 

Section 91.151 states: 

(a) No person may begin a flight in the airplane under VFR conditions unless (considering wind 

and forecast weather conditions) there is enough fuel to fly to the first point of intended 

landing and, assuming normal cruising speed, 

(1) During the day, to fly after that for at least 30 minutes; or 

(2) At night, to fly after that for at least 45 minutes. 

The battery powering the sUAS provides less than 30 minutes of powered flight, and the sUAS 

will not be flown at night. An exemption from the 30 minute reserve requirement in 14 C.F.R. § 

91.151 is therefore required. 
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Equivalent Level of Safety 

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An equivalent level of safety can be achieved by limiting flights to rated flight time or 25% of 

remaining battery power, whichever happens first. This restriction would be more than 

adequate to return the sUAS to its planned landing zone from anywhere within its limited 

operating area. Operation of the sUAS 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 sUAS. Moreover, operation will be limited to controlled areas where only 

people and property owners, or official representatives who have signed waivers and 

permissions will be allowed. 

This request for exemption falls within the scope of prior exemptions. See Exemption 10673 

(allowing Lockheed Martin Corporation to operate without compliance with§ 91.151(a)). Other 

examples of exemptions include Exemptions 2689F, 5745, 10673 and 10808. 

M. 14 C.F.R. § 91.203(a) and (b) Carrying Civil Aircraft Certification and Registration 

This petition seeks an exemption from civil aircraft certification and registration requirements of 

14 C.F.R. § 91.203 (a) and (b). 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) ofthis 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. 

In addition to the fact that Petitioner is seeking an exemption from the airworthiness certificate 

display, load capacity and size does not allow it to carry certification and registration 

documents; (2} the sUAS does not have a cabin or cockpit entrance at which the documents 

could be displayed; and (3} there are no passengers or crew for whom the certificates need to 

be displayed. 

Equivalent Level of Safety 

To the extent these regulations are applicable to the proposed sUAS operations, 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. 

As examples, the FAA has issued numerous exemptions to this regulation. A representative 

sample of other exemptions include, Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797 A, 

9816A and 10700. 

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N. 14 C.F.R. §§ 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a) and (b); Maintenance Inspections 

This petition seeks an exemption from the maintenance inspection requirements of 14 C.F.R. §§ 

91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance 

and inspection standards in reference to 14 C.F.R. 43. 

14 CFR 91.405 (a) - Maintenance Required 

This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore these 

sections will not apply. 

In the absence of regulatory provisions dealing with sUAS operation for maintenance required, 

Petitioner has included maintenance and inspection procedures in its Operations and Training 

Manual which is attached to this Petition. These procedures are consistent with the 

manufacturer's recommendation and best practices regarding sUAS maintenance, inspection 

and recordkeeping . 

Recommendations for maintenance required: 

1. Maintenance will be accomplished by Petitioner pursuant to the 

manufacturer'recommendations and Petitioner's Operations and Training Manual. 

2. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully 

accomplished by trained personnel only. 

3. The Petitioner's sUAS Operations and Training Manual includes the Inspection Program which 

details how to enter worked preformed in the maintenance log for scheduled, unscheduled 

maintenance or functional test flights that are performed. 

4. Petitioner shall only operate its sUAS with all systems functioning per manufacture's 

specification in a discrepancy free condition. 

5. These records will be maintained at the principle base for operation for the life of the aircraft 

or as required by Federal Aviation Regulations. 

Petitioner and the Aircraft Manufacturer (DJI) are the most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition. This maintenance process allows for an 

equivalent level of safety to be achieved due to the limited size, scope and area of operations. 

14 CFR 91.407 (a) (1)- Operation after Maintenance, Preventive Maintenance, Rebuilding or 

Alteration 

This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore these 

sections will not apply. 

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In the absence of regulatory provisions dealing with sUAS operation after maintenance, 

preventive maintenance, rebuilding, alteration or functional test flights, Petitioner has 

developed requirements to address these topics, which are contained in Petitioner's sUAS 

Operations and Training Manual, Inspection Program and Manufacturer's User Guides. 

1. Maintenance will be accomplished by Petitioner pursuant to the manufacturer's 

recommendations and Petitioner's sUAS Operations and Training Manual and Inspection 

Program. 

2. Maintenance, preventive maintenance, rebuilding and alteration will be successfully 

accomplished by trained personnel only. 

3. Functional test flights will be performed by the PIC when required, the sUAS shall only be 

returned to service when this functional test flight is successfully completed. If a mechanical 

issue arises the sUAS can land safely or be recovered within the Operations Area. 

4. The Petitioner's sUAS Operations and Training Manual details how to enter in the 

maintenance log scheduled and unscheduled maintenance or functional test flights that are 

performed. 

5. Petitioner shall only operate its sUAS with all systems functioning per manufacturer's 

specification in a discrepancy free condition. 

6. These records will be maintained at the principle base for operation for the life of the aircraft 

or as required by Federal Aviation Regulations. 

Petitioner and the Aircraft Manufacturer (OJ I) are the most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition. These maintenance procedures allow 

for an equivalent level of safety to be achieved due to the limited size, scope and area of 

operations. 

14 CFR 91.409 (a) (1) and (2) -Inspections 

This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore these 

sections will not apply. 

In the absence of regulatory provisions dealing with sUAS operation and Inspections, Petitioner 

has developed requirements to address these topics, which are contained in Petitioner's sUAS 

Operations and Training Manual, Inspection Program and Manufacturer's User Guides. 

1. Maintenance will be accomplished by Petitioner pursuant to the manufacturer's 

recommendations and Petitioner's sUAS Operations and Training Manual and Inspection 

Program. 

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2. Maintenance, preventive maintenance, rebuilding and alteration will be successfully 

accomplished by trained personnel only. 

3. The Petitioner sUAS Operations and Training Manual details how to enter into the 

maintenance log all inspections that are performed. 

4. Functional test flight will be performed by the PIC when required after inspections, the sUAS 

shall be returned to service when the flight is successfully completed. If a mechanical issue 

arises the sUAS can land safely or be recovered within the Operations Area. 

5. Petitioner shall only operate its sUAS with all systems functioning per manufacturer's 

specification in a discrepancy free condition. 

6. These records will be maintained at the principle base for operation for the life of the 

aircraft or as required by Federal Aviation Regulations. 

Petitioner and the Aircraft Manufacturer (DJI) are the most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition. 

These maintenance inspections allow for an equivalent level of safety to be achieved due to the 

limited size, scope and area of operations. 

14 CFR 91.417(a) and (b)- Maintenance Records 

This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore these 

sections will not apply. 

In the absence of regulatory provisions dealing with sUAS maintenance records, Petitioner has 

developed requirements to address this topic, which are contained in Petitioner's sUAS 

Operations and Training Manual, Inspection Program and Manufacturer's User Guides. 

1. Maintenance will be accomplished by Petitioner pursuant to the manufacturer's 

recommendations and Petitioner's sUAS Operations and Training Manual. 

2. Maintenance, preventive maintenance, rebuilding and alteration maintenance recordkeeping 

will be performed by trained personnel and entered in the respective aircraft maintenance 

log at completion of each event. The Petitioner's sUAS Operations and Training Manual 

details how entries are to be made in the aircraft maintenance log for scheduled and 

unscheduled maintenance or functional test flights that are performed. 

3. These records will be maintained at the principle base for operation for the life of the aircraft 

or as required by Federal Aviation Regulations. 

Petitioner and the Aircraft Manufacturer (DJI) are the most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition. 

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These maintenance records allow for an equivalent level of safety to be achieved due to the 

limited size, scope and area of operations. 

Equivalent level of Safety 

In summary regarding the exemptions requested under 14 C.F.R. §§ 91.405(a}, 91.407(a)(l}, 

91.409(a}(2), and 91.417(a) and (b), an equivalent level of safety will be achieved because 

maintenance and inspections will be performed in accordance with Petitioner's Operations and 

Training Manual and Inspection Program section. As provided in the Manual, the operator will 

insure that the sUAS is in proper working order prior to initiating a flight, perform required 

maintenance and keep a log on any maintenance performed. The Operator and the Aircraft 

Manufacturer (DJI) are the most familiar with the aircraft and are best suited to maintain the 

aircraft in an airworthy condition. If mechanical issues arise, the sUA$ can land immediately and 

will be operating from no higher than 400 feet AGL. Moreover, the sUAS's small size, carrying 

capacity, and the fact that flight operations will only take place in restricted areas for periods of 

time not to exceed 25 minutes or until 25% battery power remains, create less risk than the 

same factors associated with conventional fixed-wing and rotorcraft performing the same 

operation. 

Public Interest 

Consistent with the requirements of 14 C.F.R. §§ 11.81(d}, Petitioner offers the following reasons why 

granting this petition is in the public interest, i.e., how granting it would benefit the public as a whole. 

Approval of exemptions allowing commercial operations of small and lightweight sUAS in the 

photography and videography industries benefits the public as a whole in the following ways: 

(1) It helps fulfill Congress' goal in passing Section 333 (a} through (c) of the Reform Act, namely, 

the FAA Administrator's assessment of whether certain sUAS may operate safely in the National 

Airspace System before completion of the rulemaking required under Section 332 ofthe Reform 

Act. 

(2) The operation significantly improves safety and reduces risk by alleviating human exposure to 

danger associated with current aerial survey and inspection, namely, full-sized helicopters. 

Manned helicopters performing photography or videography have experienced an increasingly 

high number of accidents and fatalities. Helicopter crashes have taken more lives on film sets 

than any other type of accident in modern times. Since 1980, 33 film and TV workers have been 

killed in helicopter accidents around the world, 14 in the U.S. and 15 more for American 

companies shooting abroad, according to a "Deadline Hollywood" article. The public's interest is 

furthered by reducing human exposure to death or serious injury associated with manned 

aircraft performing these services. 

(3} Petitioner's uUAS's are battery powered and create no emissions. If Petitioner's sUAS crashes, 

there is no fuel to ignite or explode. Any impact of Petitioner's lightweight sUAS is, obviously, 

far less than a full-sized helicopter. The public's interest is furthered by minimizing ecological 

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impact of an accident and by reducing human exposure to potentially harmful emissions 

associated with manned aircraft. 

(4) Aerial photography and videography are valuable tools for urban projects, real estate and 

artistic production. The use of sUAS addresses safety problems and is a powerful tool for 

performing a wide-range of photography and videography that is either inaccessible by 

traditional aircraft or provides a significant safety benefit. The public as a whole will benefit 

from the safer and more cost-effective photography and videography services that sUAS 

operations provide. 

Privacy 

All flights will occur over private or controlled access property with the property owner's or controlling 

authority's prior consent and knowledge. Filming will be of people who have also consented to being 

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

Federal Register Summary 

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: 

Petitioner seeks exemption from the following rules: 

14 C.F.R. Part 21, Subpart H; 14 C.F.R. Part 27; 14 C.F.R. 45.23(b); 14 C.F.R. § 61.113(a) and (b); 14 C.F.R. 

91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.103; 14 C.F.R. 91.105; 14 C.F.R. 91.109(a); 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); 14 C.F.R. 91.407(a)(1); 

14 C.F.R. 91.409(a)(2); and 14 C.F.R. 91.417(a) and (b). 

Approval of exemptions allowing commercial operations of small and lightweight unmanned aircraft 

("sUA$") in the photography and videography industry will enhance safety by reducing risk. 

Conventional operations in this industry using rotorcraft or fixed-wing aircraft present the risks 

associated with vehicles that weigh in the neighborhood of several thousand pounds and carry large 

amounts of fuel. Such aircraft must fly to and from the survey or inspection location and operate at low 

altitudes. In contrast, a sUAS weighing fewer than 55 pounds and powered by batteries eliminates 

virtually all ofthat risk, given the reduced mass and lack of combustible fuel carried onboard. The sUAS 

is transported, not flown, to the designated imaging area and set up. The sUAS carries no passengers or 

crew and, therefore, does not expose them to the risks associated with manned aircraft flights. 

The operation of small sUAS's, weighing less than 55 pounds, provides an equivalent level of safety and 

thus supports the grant of the exemptions requested herein, including exempting the Petitioner from 

the requirements of Part 21 and allowing commercial operations. These lightweight sUAS's operate at 

low speeds, close to the ground, and in a sterile environment. As a result, they are far safer than 

conventional aerial photography or videography operations conducted with fixed-wing aircraft or 

helicopters. 

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Conclusion 

Cooley Drone Services 

Small Unmanned Aerial Systems 

Aerial Photography and Videography 

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

The size, weight, speed, operating capabilities, proximity to airports and populated areas, and operation 

within visual line-of-sight provides equivanent levels of safety as required in Part 333. In addition, 

providing the requested exemptions is in the public interest and creates no threat to national security. 

Therefore, the Petitioner respectfully requests that the requested exemptions be granted allowing the 

Petitioner the opportunity to operate sUAS's in the National Airspace System for commercial operations 

in a safe and professional way. 

If any additional information is required, or if you have any questions regarding this petition, please 

contact the undersigned Petitioner. 

Sincerely, / /') 

;.:7c;:; 

//~4:5 - Attachments (All Subject to Non-Disclosure under the Freedom of Information Act, 5 U.S.C. § 552 et. 

Seq.): 

Attachments: 

(1) DJI Phantom 2 Vision Plus User's Manual 

(2) DJI Phantom 3 User's Manual 

(3) DJI Phantom Pilot's Training Guide 

(4) DJI Phantom 3 Safety Guide 

(5) Cooley Drone Services Operations and Training Manual 

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