May 15,2015 U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 

# Cooley Drone Services SmallUnmannedAerialSystems AerialPhotographyand Videography

Re: Petition of Edward Cooley, dba Cooley Drone Services, for Exemption to Section 333 ofthe FAA Modernization and Reform Act of2012 To Whom It May Concern: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 ("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 ofsmall 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 ofthe 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 ofOperations for Tampa International Airport and an instrumentrated private pilot with over 3,000 hours offlight time. Petitioner has been an aircraft ownerfor over thirtyyears and a pilot operating in the National Airspace System for overforty-four years. Petitioner is starting up a new aviation business offering aerial photography and videography with the use ofsUAS. Specifically, Petitioner wishes to provide aerial photography for building inspections, real estate sales services, commercial photography and videography services, and sUAS flight demonstration

# Cooley Drone Services Small UnmannedAerialSystems AerialPhotography and Videography 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 ofthe Petitioner is: Edward Cooley 18921 Chaville Rd. Lutz, FL 33558 813 948-7001 (Home) 813 389-7647 (Cell) email: Relevant StatutoryAuthority 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 ofthat law, directed the Secretary ofTransportation ("FAA Administrator") to consider whether certain unmanned aircraft systems may operate in the National Airspace System ("NAS") before completion ofthe rulemaking required underSection 333 ofthe Reform Act. In making this determination, the Secretary is required to determine which types ofsUAS's do not create a hazard to users ofthe NAS orthe public or pose athreat to national security in light ofthe following: The sUAS's size, weight, speed and operational capability; operation ofthe sUAS in close proximity to airports and populated areas; and, operation ofthe sUAS's within visual line ofsight ofthe operator. Ifthe Secretary determines that such vehicles "may operate in the National Airspace System, the Secretary shall establish requirements forthe safe operation ofsuch 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 whythe 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 ofthe Reform Act The proposed operations in this petition for exemption qualifyfor expedited approval underSection 333 ofthe Reform Act. Each ofthe statutory criteria and other potentially relevant factors are satisfied. The proposed operations would permitthe use ofsmall 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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# Cooley Drone Services Small UnmannedAerialSystems AerialPhotographyand Videography {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 capabilityto 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 ofthe National Airspace System orthe public." Given the small size ofthe sUAS's involved and the restricted sterile environment within which they will operate, this petition for exemption falls squarely within that zone ofsafety, 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 ofthe application presents no national security issue. Considering the clear direction in Section 333 ofthe 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 ofthe requested exemptions is also in the public interest. Accordingly, Petitioner respectfully requests that the FAA grantthe 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 ofoperational lim itations and conditions which will insure an equivalent or higher level ofsafety to operations conducted under current regulatory guidelines. The sUAS aircraft that are proposed to be utilized under this grant ofexemption are the OJI Phantom Vision 2 Plus and the DJI Phantom 3. Detailed information on these aircraft is included in the attachments ofthis petition. 

### 1. The sUAS will weigh less than 55 pounds with payload. 2. The sUAS will not operate at a speed greaterthan 87 knots {100 mph). 3
. Flights will operate within line-of-sight ofthe pilot and visual observer. 4. Maximum total flighttime for each operational flight will be 25 minutes. Flights will be terminated at 25% battery power reserve, should that occur priorto 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 ofa Pilot and a Visual Observer ("VO").



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# Cooley Drone Services SmallUnmannedAerialSystems AerialPhotographyand Videography The sUAS pilot will be the Pilot in Command ("PIC"). Ifa 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 priorto each day's activities. It will be mandatorythat all personnel who will be performing duties within the boundaries ofthe 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 itsterms, this statutory authority includes exempting civil aircraft, as the term is defined under§ 40101 ofthe 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 grantof 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 ofsafety 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 ofthe Reform Act.



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# Cooley Drone Services Small UnmannedAerialSystems AerialPhotographyand Videography The Federal Aviation Act (49 U.S.C. § 44701(f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability and proximity to airports and populated areas ofthe particular sUAS
. In all cases, an analysis ofthese 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 ofthe proposed sUAS operations. Equivalent Level ofSafety The sUAS to be operated hereunder weighs less than 55 pounds fully loaded, carries neither a pilot nor passengers, carries no explosive materials orflammable 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 tothe 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 ofsafety 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 ofoperation, location ofoperation, lack of explosive materials orflammable liquid fuels and inabilityto 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 extentthe 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 Hwould apply
. C. Aircraft Marking and Identification Requirements: 14C.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 ofthis chapter
. 

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# Cooley Drone Services

14 C.F
.R. § 45.23(b), Marking ofthe Aircraft, states: Small UnmannedAerialSystems AerialPhotographyand 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 ofthe cabin, fuselage, boom, ortail , 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 ofthe 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 ofthe specific reliefsought by this exemption request, Petitioner requires relieffrom the associated marking and identification requirements of§45.27(a) and § 91.9(c), which would require compliance with§ 45.23(b). Equivalent Level ofSafety An equivalent level ofsaf ety 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 ofthe sUAS as "Experimental"
. Additionally, Petitioner will ensure compliance with any requests ofsUAS marking bythe FAA. As examples, the FAA has issued th e 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) ofthis section, no person who hold sa private pilot certificate may act as pilot in command ofan aircraftthat is carrying passengers or property for compensation or hire, nor may that person, for compensation or hire, act as pilot in command ofan aircraft.

# Cooley Drone Services Small UnmannedAerialSystems AerialPhotographyand 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 pilotto 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 underthis 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 tothe business to benefit from the exception. Equivalent L evel ofSafety Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level ofsafety to§ 61.113(a) and (b), by requiring the PIC operating the sUAS to have the training on operation ofthe 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 ofoperation is controlled and restricted, and all flights are planned and coordinated in advance. The risks associated with the operation ofsmall, 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 sUASto have training on operation ofthe 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 ofsafety 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 14C.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 ofthis chapter, un less there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual materials, markings, and placards orany combination thereof. Given the size, configuration, and load capacitythe sUAS has no ability to carry such a manual on the aircraft, notonly 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 ofSafety 

# Cooley Drone Services Small UnmannedAerialSystems AerialPhotography and Videography
The safety-related purpose ofthis manual requirement can be equally satisfied by maintain ing 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 atthe 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): C ivil AircraftAirworthiness 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 ofSafety Given the size ofthe sUAS and the requirements contained in the sUAS Operations and Training Manual for maintenance and use ofsafety checklists priorto 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 fl ight, including information contained in the FAA approved F light Manual on board the aircraft. Inasmuch as the FAA approved F light Manual will not be provided for the sUAS, an exemption will be needed
. Equivalent Level ofSafety 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 takeoffdistances, and aircraft performance data, before initiatingthe 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 harnessfastened unless the absence is necessary to perform duties in co nnection with the operation ofthe aircraft, or in connection with physiological needs. Inasmuch as sUAS are 

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# Cooley Drone Services Small UnmannedAerialSystems AerialPhotography and Videography 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 ofSafety Given the size and operational characteristics ofthe 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 ofa control box that communicates with the sUAS via radio communications
. Equivalent Level ofSafety Given the size and speed ofthe sUAS, an equivalent level ofsafe training can still be performed without dual controls because no pilot or passengers are onboard 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 ofaircraft 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 otherthan congested areas, an altitude of500 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) ofthis 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 ofcommercial 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 ofService 

# Cooley Drone Services Small UnmannedAerialSystems AerialPhotographyand Videography Compared to flight operations with rotorcraft weighing far more than the maximum of 55 pounds proposed herein, and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft. An equivalent level ofsafety will be achieved given the size, weight, speed ofthe sUAS as well as the location where it will be operated. The sUAS will be operated in a res tricted 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 ofthe 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 orflight level by reference to an altimeterthat is set to the elevation ofthe 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 ofsafety will be achieved by following the procedures set forth in the Operations and Tra ining Manual. As prescribed in the Manual, the operator will confirm the altitude ofthe 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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## I a 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 underVFR 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 afterthat 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.

# Cooley Drone Services Equivalent Level ofSafety Small UnmannedAerialSystems AerialPhotography and Videography


### An equivalent level ofsafety 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 anywhe re within its limited operating area. Operation ofthe 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 ofthe 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 ora 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 ofSafety To the extent these regulations are applicable to the proposed sUAS operations, an equivalent level ofsafety will be achieved by keeping these documents atthe ground control point where the pilotflying the sUAS will have immediate access to them. As examples, the FAA has issued numerous exemptions to this regulation. A representative sample ofother exemptions include, Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 

### 9816A and 

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# Cooley Drone Services Small UnmannedAerialSystems AerialPhotographyand Videography 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 14C.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, rebu ilding, and alteration will be successfully accomplished by trained personnel only. 3. The Petitioner'ssUAS Operations and Training Manual includesthe Inspection Program which details how to enterworked preformed in the maintenance log for scheduled, unscheduled maintenance orfunctional tes t flights that are performed
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. 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 ofthe aircra ft or as required by Federal Aviation Regulations. Petitioner and the Aircraft Manufacturer (DJI) are the mos t familiar with the aircraft and bes t suited to maintain the aircraft in an airworthy condition. This maintenance process allows for an equ ivalent level ofsafety to be achieved due to the limited size, scope and area ofoperations. 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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# Cooley Drone Services Small UnmannedAerialSystems AerialPhotography and Videography In the absence of regulatory provisions dealing with sUAS operation after maintenance, preventive maintenance, rebuilding, alteration orfunctional 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. Ifa 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 howto enter in the maintenance log scheduled and unscheduled maintenance orfunctional 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 atthe principle base for operation for the life ofthe aircraft or as required by Federal Aviation Regulations. Petitioner and the Aircraft Manufacturer (OJI) 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 safetyto 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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# Cooley Drone Services Small UnmannedAerialSystems AerialPhotographyand Videography 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 intothe 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
. Ifa 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 discrepancyfree condition. 6
. These records wi ll be maintained atthe principle base foroperation forthe life ofthe 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 ofsafety to be achieved due to the limited size, scope and area ofoperations. 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'ssUAS 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 ofeach 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 orfunctional test flights that are performed
. 3
.These records will be maintained at the principle base for operation for the life ofthe aircraft or as required by Federal Aviation Regulations. Petitioner and the Aircraft Manufacturer (DJI) are the most familiarwith the aircraft and best suited to maintain the aircraft in an airworthy condition.

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# Cooley Drone Services SmallUnmannedAerialSystems Aerial Photographyand Videography These maintenance records allow for an equivalent level of safety to be achieved due to the limited size, scope and area ofoperations. Equivalent level ofSafety 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 thatthe sUAS is in properworking order priorto initiating aflight, perform required maintenance and keep a log on any maintenance performed. The Operator and the Aircraft Manufacturer (DJI) are the mostfamiliar 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 thatflight operations will only take place in restricted areas for periods of time notto 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}, Petitioneroffers the following reasons why granting this petition is in the public interest, i.e., how granting it would benefitthe public as awhole. Approval ofexemptions 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 helpsfulfill Congress' goal in passing Section 333 (a} through (c) ofthe Reform Act, namely, the FAA Administrator's assessment ofwhether certain sUAS may operate safely in the National Airspace System before completion ofthe 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 cu rrent aerial survey and inspection, namely, full-sized helicopters. Manned helicopters performing photography orvideography have experienced an increasingly high number of accidents and fatalities. Helicopter crashes have taken more lives on film sets than any othertype 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 forAmerican 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 afull-sized helicopter. The public's interest is furthered by minimizing ecological


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# Cooley Drone Services Small UnmannedAerialSystems AerialPhotography and Videography impact of an accident and by reducing human exposu re 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 ofsUAS 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 orotherwise 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 shou ld 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; 14C.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 ofexemptions allowing commercial operations ofsmall and lightweight unmanned aircraft ("sUA$") in the photography and videography industry will enhance safety by reducing risk. Conventional operations in this industry using rotorcraft orfixed-wing aircraft present the risks associated with vehicles that weigh in the neighborhood ofseveral thousand pounds and carry large amounts offuel. 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, notflown, 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 ofsmall sUAS's, weighing less than 55 pounds, provides an equivalent level ofsafety and thus supports the grant ofthe exemptions requested herein, including exempting the Petitionerfrom 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 orvideography operations conducted with fixed-wing aircraft or helicopters.



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### Conclusion 

# Cooley Drone Services Small UnmannedAerialSystems AerialPhotography and Videography

Satisfaction ofthe criteria provided in Section 333 ofthe 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 Petitionerthe opportunityto operate sUAS's in the National Airspace System for commercial operations i n a safe and professional way. If any additional information is required, or ifyou have any questions regarding this petition, please contact the undersigned Petitioner. 

### Sincerely, / /')



# //~4:5 

# ;.:7c;:;
- Attachments (All Subject to Non-Disclosure underthe 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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