November	29,	2015

United	States	Department	of	Transportation Docket	Management	System 1200	New	Jersey	Ave.,	SE Washington,	DC	20590
**Re:		Exemption	Request	Pursuant	to	Section	333	of	the	FAA	Reform	Act	of 2012** 

Dear	Sir	or	Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and C.F.R. Part 11, Timothy Cocrane dba RC Skytography (hereinafter	petitioner	or	operator) of	Small	Unmanned	Air	Aircraft	Systems	(UASs), request to be exempted from the Federal Aviation Regulations (FARs) listed below
so that Timothy Cocrane dba RC Skytography may operate UASs commercially in airspace regulated by the Federal Aviation Administration; as 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.
Timothy Cocrane dba RC Skytography is a family operated business with a wide range of flying experience. The flight experience ranges from a professional Pilot with Airline Transport Pilot privileges for a major airline and military flight time combining for over 18,000 hours. Additional family members have acquired flight experience and private pilot licenses in glider, fixed wing
, and helicopter. All UAV operations will be in accordance with RC Skytography’s Standard Operating Procedures	(SOPs)	or	as	established	by	the	FAA.
The	Name	and	address	of	the	applicant	is:
Timothy	Cocrane	dba RC	Skytography Attn:		Timothy	Cocrane Phone:		704

-661

-1126 Email:timcocrane@att.net Address:		20511	Pointe	Regatta	Drive,	Cornelius,	North Carolina	28031

As described below, the requested exemption would permit the operation of lightweight (less than 55 lbs. total take off gross weight) UASs under controlled conditions for commercial use by professional certified pilots thereby enhancing safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “....establish requirements for the safe operation of such aircraft systems	in	the	national	airspace	system.” Section	333	(c)	of	the	Reform	Act.Timothy Cocrane dba RC Skytography respectfully requests the grant of an

exemption to the following specific sections of the Title 14 code of federal Regulations	allowing	it	to	operate	lightweight	UAS’s	for	commercial	use:

14 CFR 21 subpart H
, 14 CFR 45.23(b), 14 CFR 61.113 (a&b), 14 CFR 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).

The requested exemption would permit commercial operation of Timothy Cocrane dba RC Skytography to operate the Yuneec Typhoon Q500 4K quad

-copter unmanned aircraft system (UAS) to conduct aerial videography and photography of real estate, construction sites, inspections, special events, and for marketing/advertising. The UAS operate at a speed ofless than 50 knots and have the capability to hover and move in the vertical and horizontal plane simultaneously.		The	UAS	will	operate only	within	the	line	of	sight of	the	pilot	within

a protected flight area. The UAS takes a series of high quality, still digital images and video that are used to promote real estate sales to include marketing and advertising and survey properties. Additional aerial photography may include constructions sites, roof inspections and aerial video/photography of sporting events or weddings. Use ofthe UAS for aerial inspections reduce the need to utilize conventional manned aircraft, manned lifting devices or manned climbing for the same	purposes	and	provides	very	high	quality	imagery	at	a	fraction	of	the	cost. Such operations will insure that the UASs will not create a hazard to the users of the national	airspace	system	or	the	public.
Timothy Cocrane dba RC Skytography submits this application to grant exemption for use ofthe proposed UAS’s for commercial use of aerial photography and inspections and will advance the Congressional mandate in Section 333 of the Reform Act to accelerate the introduction of the UASs into the national airspace system (NAS). The law directs the Secretary ofTransportation to consider whether certain	unmanned aircraft	systems	may	operate	safely	in	the	NAS	before	completion ofthe rulemaking required underthe Section 332 ofthe ReformAct.In makingthis determination, the Secretary is required to determine which types of UASs do not create	a	hazard	to	users of	the	NAS	or	the	public	or	pose	a	threat	to	national	security in	light	of	the	of	the	following:

- The	UAS’s	size,	weight,	speed	and	operational	capability

- Operation	of	the	UAS	in	close	proximity	to	airports	and	populated	areas

- Operation	of	the UAS	within	visual	line	of	sight	of	the	operator

Reform Act 333 (a). If the secretary determines that such vehicles “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.”

The small nature of the UASs that are utilized by Timothy Cocrane dba RC Skytography combined with the safety protocols outlined below will allow for agreater than equivalent level of safety in which Congress envisioned that the FAA

must, by exemption allow commercial operations of UASs. Also due to the size of the UASs and the areas and altitudes they will operate, approval of the exemption presents no national security issues and absolutely minimal safety concerns. Given the	clear	direction	given	in	Section	333	of	the	Reform	Act,the	authority	contained	in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, the significant public benefit, including enhanced	saf

ety,	reduced	emissions	utilizing	UASs	vice	traditional	aircraft	as	well	as the economic impact of greatly reducing cost of aerial photography thereby benefiting	the	greater	public’s	interest.

The following limitations are considered to be binding for the operations of UASs	for	commercial	purposes	byTimothy	Cocrane	dba RC	Skytography:

1. Flights will be operated in the visual line

-of

-sight (VLOS) by the pilot in command. 2. Flights	will	only	occur	in	the	daytime	and	clear	of	clouds. 3. The	UASs	will	weight	lessthan	55lbs	at	take	off	and	during	flight. 4. Flights	will	be	terminated	with 25%	of	battery	life	remaining. 5. Flights	will	be	operated	at	an	altitude	at	or	below	allowedAGL. 6. Pilots,	camera	operators	and	observers	will	be	trained	IAW	the	applicable portion	of	the	UAS’s	manual	as	well	as	the	SOPs. 7. Minimum UAS crew will be one certificated private pilot or higher rating with a current FAA medical. Acamera operator and or observer may be added as required to further reduce the possibility oftask saturation by the	pilot. 8. Pilot, observer and camera operator will maintain real time communication	capability	throughout	flight	operations. 9. The UAS Pilot will conduct a full site survey to determine the Area of Responsibility	(AOR).		This	AOR	is	the	actual	area	for	UAS operations	for	a particular day. Each survey will include the assessment of potential hazards to include but not limited to airspace classifications, temporary flight restrictions, closest airport proximity, natural and manmade obstacles, and unnecessary persons which may pose a risk to operations

or safety. Ifdeemed necessary, the crew will employ additional personal as	safety	observers. 10.A	thorough	briefing	will	be	conducted,	prior	to	the	first	flight	of	the	day	in an	AOR,	utilizing	the	briefing	guide	in	the	SOPs. 11. Timothy Cocrane dba RC Skytography will obtain consent (written or verbal) for any persons who need to be within 100 feet of UAS flight operations. 12.Written and orverbal permission fromthe relevant property owners will be	obtained	prior	to	flight. 13.All required permissions and permits would be obtained from territorial, state,	county	or	city	jurisdictions,	including	local	law	enforcement,	fire,	or other	governmental	agencies.14. Ifthe	UAS	loses	communications	or	loses	its	GPS	signal,	the	UAS	will have the capability to return to a pre
-determined location within the AOR and land	autonomously. 15. The UAS will have the ability to abort a flight in case of unpredicted obstacles	or	emergencies.

**14 C.F.R.**  **Part 21**  **Subpart H:**  **A irworthiness**  **Certificates 14**  **C.F.R. 91.7(a),**  **91.203(a)(1)**
Subpart	H,	entitled	Airworthiness	Certificates,	sets	forth	requirements for procurement of necessary airworthiness certificates in relation to FAR 91.230(a)(1) The size, weight and defined area of operations for RC Skytography UAS flights permits exemption for Part 21 because RC Skytography meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness	certificate	requirement	under	both	the	ACT (49	U.S.C.	44701(f) and Section 333 ofthe ReformAct.Both pieces oflegislation permitthe FAA to exempt UASs from the airworthiness certificate requirement in consideration ofweight, size, speed, maneuverability and proximity to areas such as airports and dense populations. Timothy Cocrane dba RC Skytographymeets	or	exceeds	each	of	these	elements.

14 C.F.R 91.203 (a&b) provides for carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons stated above. The equivalent level of safety will be achieved by maintaining such certifications and registrations at Timothy Cocrane dba RC Skytography operations	center.

14 C.F.R 91.7(a) prohibits the operation of an aircraft without an airworthiness	certificate.		As	no	such	certificate	will	be	applicable	in	the	form contemplated	by	the	FARs,	this	regulation	is	inapplicable.
**14	C.F.R.	45.23	Marking	of	the	Aircraft**

14 C.F.R. 45.23 : Applicable Codes of Federal regulations require aircraft to be marked according to certain specifications. Timothy Cocrane dba RC Skytography UASs are unmanned; do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Timothy Cocrane dba RC Skytography will, however, place the world “experimental” on its exterior of the UAS, if required by the FAA. However, due to the size, two

inch	lettering	is	impractical	to	place	on	such	small	aircraft.**14	C.F.R.	61.113	(a&b)		Private	Privileges	and	Limitations:	Pilot	in	Command**

14 C.F.R 61.113 (a&b): Unlike civil aircraft, the UAS does not carry living things on board; rather, it is controlled remotely via a safe and restricted location. The risks during operation are so minuscule that the PIC will exceed the present level ofsafety required for a commercial pilotto operate a rotorcraftwith a commercial	license.
**14	C.F.R.	91.9(b)(2)	Civil	Aircraft	Flight	Manual	in	the	Aircraft**

14 C.F.R. 91.9(b)(2) requires an aircraft flight manual in the aircraft. As there are no pilots of passengers, and given the size of the UASs, this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining an operators manual at the operations center. The FAA has previously	issued	exemptions	to	this	regulation.
**14	C.F.R.	91.103(b )	Preflight** **action s** 

14	C.F.R.91.103	Each pilot	in	command	shall,	before	beginning	a flight, become familiar with all available information concerning that flight. This information must include: (b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information. This	subparagraph	is	not	applicable	due	to	our	off	airfield	operation.

**14 C.F.R.**  **91.109 Flight**  **instruction: S** **imulated instrument**  **flight and**  **certain flight	tests** 

14 C.F.R. 91.109 and all the subparagraphs address the operation ofa civil manned aircraft in conjunction with the training and flight tests. The UAS to be employed by Timothy Cocrane dba RC Skytography are not designed	in	this	category.
**14	C.F.R.	91.121	Altimeter	Settings**

14 C.F.R. 91.121 regarding altimeter settings is inapplicable because Timothy Cocrane dba RC Skytography UASs utilize GPS systems and interval gyroscopes	to	provide	spatial	stability	and	reference	datum.
**14	C.F.R.	91.151	Fuel	Requirements	for	Flight	in	VFR	Conditions**

14 C.F.R 91.151 prohibits an individual from beginning a “flight in an 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 UAS provides approximately 25 minutes of powered flight,which is lessthanthe reserve requirement alone by FARs for day or night VFR flight. Given the limitations on the UAS’s flight envelope, proposed AOR size, battery life and its ability to land immediately it is reasonable	to	allow	an	exception. An	equivalent	level	of	safety	can	be	achieved	by	limiting	flights	to	25% of battery power. This restriction would be more than adequate to return the	UAS	to	its	planned	landing	zone	in	the	AOR.

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

14 C.F.R.91.119 prescribe safe altitudes for the operation ofcivil aircraft.It allows helicopters to be operated at lower altitudes in certain conditions. Timothy Cocrane dba RC Skytography will only operate its UASs at or below 400 AFL. Timothy Cocrane dba RC Skytography will operate its UASs in definedAOR that has been carefully reviewed for hazards and minimizes the presences ofany person not essential for operations. Flights will only be conducted over private property with consent	of	the	property	owner.		The	equivalent	level	of	safetywillbe	achieved	given the size
, weight and speed of the UAS as well as the location where it is operated. Compared to flight operations with traditional aircraft or rotorcraft weighting far

more than 55 lbs.
, operation below 500 AGL with flammable fuel UAS operations presents	afar	smaller	risk.
**14	C.F.R.	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 the aircraft inspected	as	prescribed	in	subpart	E	of	this	part	and	shall	between	required inspections,	except	as	prescribed	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. These regulations only apply to aircraft with an airworthiness certificate. They	will	not,	therefore,	apply	toTimothy	Cocrane	dba RC	Skytography UASs	should its requested exemption be granted. As an equivalent level of safety Timothy Cocrane dba RC Skytography requires	its	pilots	to	conduct a	preflight,	through

-flight and post flight inspection ofthe UAS to ensure it’s flightworthiness prior to launch. Each UAS is flown in compliance with the applicable manufactures manual to include all software updates cycles as well as flight checklists. In the event of a malfunction	the	UAS	can	land	immediately.

**Privacy**

All flights will occur over private or controlled access property with the property	owner’s	prior	consent	and	knowledge.

**Summary**Timothy Cocrane dba RC Skytography is seeking exemption from the

following rules: 14 CFR 21, subpart H, 14 CFR 45.23 (b), 14 CFR 61.113 (a&b), 14 CFR 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).
Approval of the above exemptions allowing commercial operations of small UASs in the service of aerial photography will greatly enhance safety by reducing the overall risk associated with traditional aircraft. Traditional aerial photography requires large aircraf

t weighing thousands of pounds and carrying hundreds of pounds of fuel presenting a significant risk to life and property. With Timothy Cocrane dba RC Skytography use ofsmall UASs weighing less than 55 lbs., powered by batteries and operating at or below 400 AGL they virtually eliminate all of the risk associated with traditional aerial photography. The UASs will carry no people thereby eliminating the exposure to the risks associated with flying while accomplishing the same task in a much saf er manner. Timothy Cocrane dba RC Skytographyrespectfully	requests	that	the	FAA	grant	its	exception	without	delay.

Sincerely,

Timothy	J.	Cocrane RC	Skytography 20511	Pointe	Regatta	Drive Cornelius, NC		28031 Timothy Cocrane