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	of	less	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	of	the	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	of	the	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	of	Transportation	to	consider	whether	

certain	unmanned aircraft	systems	may	operate	safely	in	the	NAS	before	completion	

of	the	rulemaking	required	under	the	Section	332 of	the	Reform	Act.		In	making	this	

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	 a	
greater	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	safety,	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	by	Timothy	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	less	than	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	allowed AGL.

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.		A	camera	operator	and	or	observer	may	be	

added	as	required	to	further	reduce	the	possibility	of	task	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.		If	deemed	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	or	verbal	permission	from	the	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. If	the	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:	 	 Airworthiness	 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	of	the	Reform	Act.		Both	pieces	of	legislation	permit	the	FAA	

to	 exempt	 UASs	 from	 the	 airworthiness	 certificate	 requirement	 in	

consideration	of	weight,	size,	speed,	maneuverability and	proximity	to	areas	

such	 as	 airports and	 dense	 populations.	 Timothy	 Cocrane	 dba	 RC	

Skytography meets	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,	twoinch	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	of	safety	required	for	a	commercial pilot	to	operate	a	rotorcraft	with	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 actions

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:	 	 Simulated	 instrument	flight	 and	 certain	

flight	tests

14	C.F.R.	91.109	and	all	the	subparagraphs	address	the	operation	of	a	

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	less	than	the	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	of	civil 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	defined	AOR	that	has

been	carefully	reviewed	for	hazards	and	minimizes	the	presences	of	any	person	not	

essential	for	operations.		Flights	will	only	be	conducted	over	private	property	with	

consent	of	the	property	owner.		The	equivalent	level	of	safety	will	be	achieved	given	

the	size, weight	and	speed	of	the	UAS	as	well	as	the	location	where	it	is	operated.		

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	a	far	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	to	Timothy	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	of	the	UAS	to	ensure	it’s	flight	worthiness	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	 aircraft	 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	of	small	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	 safer	 manner.	 Timothy	 Cocrane	 dba	 RC	

Skytography respectfully	requests	that	the	FAA	grant	its	exception	without	delay.		

Sincerely,

Timothy	J.	Cocrane

RC	Skytography

20511	Pointe	Regatta	Drive

Cornelius,	NC		28031

Timothy 

Cocrane