Request for Section 333 Exemption.

Zachary Nathan In galls
1626 W. 21 st Street Lawrence, KS 66046 Zachary .ingalls@y ahoo.com
913

- 306

- 3424

I am seeking an exemption for my UAS, DJIPhantom 3 Professional, for the purposes of conducting aerial survey s of properties for real estate agents, as well as private propert y owners who wish to obtain my services. I am also seeking exemption so that Imay use my UAS to document historic structures using the onboard c amera. The reason behind this is to provide an alternative means of photograph y that is different from the more traditional stationary camera from the ground. It is also believed that providing video of a property provides a greater representation of the present conditions of the property and the built environment surrounding the propert y. I also wish to do aerial videograph y and photograph y for clients on a case b y case basis as desired b y the client who retains m y services.

The benefits to the public for my operation of a UAS for the purposes of documenting historic structures and aerial survey ing of properties is that it provides a different and more unique approach to learning about a property . Real estate agents, for decades, have used ground

- leve l photograph y but this can sometimes hide elements that make these properties unique and special. With a UAS, this process is dramatically changed to allow the potential buy er of the propert y to see, not just the house or building, but the surrounding lan dscape, or built environment that the structure is located in. For the purposes of documenting historic structures, using a UAS will provide an opportunity to view the condition of the structure from a much safer location than one might obtain via climbin g on to the roof or using a ladder when inspecting the present conditions of the structure. Some historic or old buildings in need of repair may

not be very

stable and the UAS provides the opportunity to closely

view the upper levels of the structure with out having to risk human life. **Operations of the Aircraft /Maintenance/Flight Checks** 

**.** 1. Operation of the UAS or Phantom will be conducted in the safest possible manner to minimize risk to the National Air Space (NAS) and to persons and propert y on the ground. Measures will be taken to ensure that no persons, aside from those associated with the operation of the UAS, are underneath the aircraft during flight. We also plan to limit the height of flight to no more than 100 feet as this allows operation of the UAS within the Visual L ine of Sight (VLOS) during flight. Should I require a secondary individual to assist during surveying and documentation, he or she will provide information as to potential obstacles should they exist and also monitor weatherconditio ns to allow for continued safe flight. That being said, he or she will not be used

to see the UAS if I can’t see it as I do not intend to have it leave m y VLOS. 2. The operational characteristics of the UAS is that it is a multi

- rotor (4 engine ) aircraft
c onstructed of rigid plastic. The aircraft lands on fixed skids and is propelled by 4 electric motors operated by an onboard battery . The aircraft also carries a 4K/12MP camera mounted to a gimbal on board. The gimbal and camera are permanently attached to the UAS and can onl y be removed via mechanical fasteners (screws). 3. The UAS maximum ascent speed is 5 m/s. I t’s maximum descent speed is 3m/s. Its maximum speed is 16 m/s however it will never be flown at these maximums as Iprefer to have smooth fligh t for the purposes of m y work and what I am using this exemption for. The aircraft can reach a maximum altitude of 6,000 meters (19685 feet). However, for my purposes and for the purposes of this exemption Ido not intend to exceed 100 feet as I do not se e a reason for exceeding this height during m y work. 4. The aircraft will be operated from the ground at all times via Remote control. The camera footage is visible through an iPad or iPhone mounted to the transmitter. Stabilization and positioning of the a ircraft during flight is maintained by an onboard GPS sy stem that is integrated into the UAS electronics from the factory . No aftermarket sy stem is or will be installed. 5. Prior to any

flight, all prop blades are firml y tightened. An y chipped prop blades are replaced with new ones prior to take off. All sy stems are checked prior to take off. The UAS requires a warm

- up period during which time the gimbal sy stems for the camera are checked as is the camera. All warning lights are checked to make sure they are not inactive and all software updates have been conducted prior to the flight. Weather conditions are also checked. Wind, Rain, and Snow are conditions that will prevent a flight. I will not operate the aircraft in these conditions nor will I operat e the aircraft in the dark. Should an y s ys tems or parts not be working, I will not operate the UAS as that would potentially

endanger property , m ys elf, or those around me.
**RF**
1. The Radio Frequency (RF) spectrum used for this UAS is 2.400 GHz

- 2.483 GHz. Ma ximum distance for this signal is 3.1 miles (unobstructed, free of interference) when FCC compliant. For m y purposes to to comply with VL OS, the aircraft will not fly to this distance. Video output from the aircraft is via USB to the mobile device mounte d to the transmitter. Receiver sensitivity is

- 101 dBm +/

- 2 dBm. Transmitter power is 20 dBm per requirements of the FCC.
**Pilot & Observers**
1. I have logged man y hours in other UAS prior to the operation of m y present UAS or Phantom. These were mostly toy aircraft in nature and were not as advanced as the present UAS I am operating. They are also not for commercial use whereas this present one will be used for such reasons. 2. An observer will only be on site for property

survey s that may

require an extra se t of ey es. Reasons for this could mean, trees, power lines, or other obstructions that mightnot be noticed b y the pilot. Prior to all flights however, a site survey will be done on foot

to check for potential aerial obstacles. His or her job will also be to monitor present weather conditions for wind, rain, or snow or other conditions that could make operation of the UAS dangerous. **Intended Operations**
1. The UAS will be used for propert y survey ing for real estate companies/agents as well as for private pro pert y owners of their personal properties. Steps will be taken for safety during these flights. These will include:
a. Full walk

- around of the propert y to check for potential flight hazards b. Blocking off of flight equipment, where the ground station will be located and where the pilot will be present. This may involve orange cones or other means of protection.
c. As the pilot will be maintaining visual contact with the UAS at all times, Iwill be wearing a reflective bright colored safety vest or other means of identify ing that I am working on something and to avoid being close by for the safet y of b ys tanders who may be curious as to what is going on. If issues with too many by standers become an issue, I will immediate cease flight and if necessary , land the UAS until Ifeel I can continue without risking by standers. d. Caution tape and other signage will be emplo yed as needed depending on the size and scope of the project.
e. If the propert y is oc cupied, as in the case of a landlord owned propert y, I will ask that the landlord notify

their tenants at least a week in advance that a UAS will be operating around the property

. 2. The UAS will be used for survey ing and documenting historic buildings/structures for clients, organizations that hire me, propert y managers, etc. Steps will be taken for safet y during these flights. These will include the same safet y steps as above, except in these instances I will have an extra spotter as well as the client on hand with me during the surveying. The extra spotter and the client will be reviewing the video feed from the UAS during flight while the first spotter will be watching the UAS and I will be maintaining visual contact with the UAS as the pilot in charge ( PI C). 3. The UAS will be used for aerial videograph y and photography . These services may not be done as frequently

as the primary

reasons for the exemption request are the survey ing of properties and the documenting and survey ing of historic structures. **Proposed Maximum operating speed & altitude**
1. While the UAS is capable of speeds of 16 m/s (35 mph), for m y purposes I will more than likely

never exceed half that speed. M y speed will be more of the pace of an average walk as the purposes of my work are to document and survey and slower speeds allow for better clarit y of the videos and photographs. Operating altitude is expected to be around 100 feet maximum though I don’t plan to go much higher than 150 feet should I exceed m y desired maximum height of 10 0 feet. The likelihood of me going to 100 feet during m y work will not be likely though but it does allow for some leeway. As this ismy intended speed and altitude, distance I plan to operate near the clouds isn’t applicable though I don’t intend to ope rate the UAS in fog either. Therefore visual contact with the UAS will alway s be maintained and if the situation doesn’t allow for that, the aircraft will not fly

. **Proximity to population**
1. Since the UAS will be used to document and survey properties, the possibility of encounter with b ys tanders is high. To prevent this, as stated in previous sections of the exemption request, Iwill mark off the area that the ground station will be located and provide my self as the pilot, and my observer should Irequire one, with appropriate reflective or brightl y colored gear so as to identify that a UAS is in operation. Caution tape, signage, and orange cones will also be used as needed to mark off the location that the UAS is operating. 2. The UAS will not operate near an airport. As it is not planned to operate to operate much higher than a maximum of 150 feet, risk to aircraft will be minimal. That being said, if a potential client wants me to document or survey a propert y that borders an airport, I will obtain further authorization from the FAA, or refer the client to another UAS operator. **Compliance with VLOS and Preflight procedures**
1. To comply

with Visual Line of Sight or VLOS, the UAS will be flown in clear weather conditions with the PI C maintaining visual contact w ith the aircraft during flights and, if required, a spotter present to watch for potential obstacles and to watch the aircraft as well. 2. During start up of the aircraft, the engines run at a lower speed prior to lift

- off speed. This allows for checking of the aircraft for an ything that could potentiall y lead to problems during flight. Prior to initial start

- up, however, all mechanical components as well as the prop blades will be checked for potential debris inside the motors and for potential damage to the motors, prop blades, as well as fuselage. If an y issues exist that could adversely

affect the flight of the aircraft, the UAS will not fly until those issues are taken care of. The UAS will not be operated outside the United States.