May 17, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., 

Washington, DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations. 

Dear Sir I Madam: 

Pursuant to the Section 333 of the FAA Modernization and Reform Act of 2012 (the 

"Reform Act"), Trevor Battieste (the "applicant"), operator of an Unmanned Aircraft 

Systems ("UAS") seeks an exemption from the Federal Aviation Regulations ("FARs") to 

allow for commercial operation for aerial imaging and video of homes & properties 

applicant list for sale in the Dallas, Ft. Worth (DFW) area. 

Applicant: 

Trevor Battieste 

11601 La go Vista #1205 

Farmers Branch, Texas 75234 

Attachments: 

DJI Pilot Training 

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 (c) 

14 CFR 91.121 

14 CFR 91.203 (a) and (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) and (b) 

Extent of relief I seek, and why 

14 CFR Part 21 subpart H 
The UAS to be operated carries neither pilot nor passenger and carries no explosive 

materials or flammable liquids. Given the size, weight, speed, and limited operating area 

associated with the aircraft to be utilized, I request exception. In the restricted 

environment and under the conditions proposed operation will be at least as safe, or 

safer, than a conventional aircraft operating with an airworthiness certificate without said 

restrictions. 

14 CFR 45.23 (b) 

Due to the size of this UAS it does not have a cockpit, cabin, or pilot station on which to 

market certain words or phrases. Lettering would be very difficult to place on such a 

small aircraft and dimensions would need to be smaller than required minimum. 

Understanding the importance of lettering. I will mark my UAS with the largest possible 

letters by placing the word "Experimental" or assigned number or name, based on 

request/ruling of FAA, on UAS fuselage. The equivalent level of safety will be provided 

by having the UAS marked on its fuselage as required. 

14 CFR 91.7 (a) 

As there will be no airworthiness certificate for the aircraft, should this exemption be 

granted, no FAA regulatory standard will exist for determining airworthiness. Given the 

size of the aircraft for maintenance and use of safety check list prior to each flight an 

equivalent level of safety will be provided. 

14 CFR 91.9 (b) (2) 

Given the size and configuration, the UAS has no ability to carry a flight manual on the 

aircraft. There is no room, capacity, or pilot on board to adequately carry flight manual. 

An equivalent level of safety will be maintained by keeping the flight manual at ground 

control point where the pilot will have immediate access to it. 

14 CFR 91.103 

As FAA approved flight manuals will not be provided for the aircraft, an exemption will 

be needed. Normal procedures including but not limited to; reviewing weather, flight 

battery requirement, landing and takeoff distances, along will all of those found in 

attachment "OJ I Pilot Training". An equivalent level of safety will be provided by preflight 

protocol) to properly match the machine. 

14 CFR 91.109 

UAS and remotely piloted aircraft do not have fully functional dual controls. Flight 

control is achieved through the use of a control box that communicates with the aircraft 

via radio communications. The equivalent level of safety provided because neither a 

pilot nor passenger will be carried in the aircraft, and by the speed and size of the 

aircraft. 
14 CFR 91.113 (a) and (b) 

I can achieve an equivalent level of safety as achieved by current regulations because 

my UAS does not carry pilot nor passenger. While helpful, a pilots' license will not 

ensure remote control piloting skills. 

14 CFR 91.121 

The UAS may not have a barometric altimeter, but instead does have a GPS altitude 

read out. I believe an exemption may be needed. An equivalent level of safety is 

achieve by the operator receiving live flight data monitoring and confirming current 

altitude along with altitude of launch site shown on GPS altitude indicator. 

14 CFR 91.203 (a) and (b) 

Similar to, 14 CFR 91.9 (b) (2), given the size and configuration, the UAS has no ability 

to carry certificate and registration documents on the aircraft. There is no room, 

capacity, or pilot on board to adequately such documents. An equivalent level of safety 

will be achieved by keeping these documents, to the extent they are applicable to the 

UAS, at the ground control point where pilot has immediate access to them. 

14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (a) 

and (b) 

Given this section only applies to aircraft with an airworthiness certificate, these 

sections do not apply to this applicant. As a safety precaution, operator will perform 

preflight inspections and ensure UAS is in working condition before initiating each flight. 

Trevor Battieste is seeking relief from all FARs above preventing applicant from 

conducting aerial photography and video of real estate taken at levels less than 400ft, at 

a speeds less than 33.5 mph, and with a maximum flight time of 25 minutes,. The drone 

to be used is a DJI Phantom 2+, and the DJI 8900. At 2.74, and 17.2 pounds 

respectively, the weight of the UAS's meets the definition of "small unmanned aircraft" 

found in section 331 "The Reform Act". In order to obtain high quality photography and 

video the UAS will be used at speeds much less than it's top speed of 33.5 mph. Due to 

the UAS being battery powered, there are no combustible fuels onboard the UAS. 

Maximum flight time for both UAS's is 15 minutes for their battery life. Flights will be 

terminated with 25% battery life remaining. Given the size, weight, speed, and limited 

operating area associated with these aircrafts, I find this exception to be reasonable 

with an equivalent, or greater, level of safety to be reached by the operator. 

Safety: 

*Please see attachment "OJ I Pilot Training" for safety precautions I use for every flight. 

Aside from these practices I was given a hands on training course when I purchased my 

UAS. 
Additionally: 

1) I do not operate within 5 miles of an airport unless prior contact to Air Traffic Control 

or the airport manager has been made. 

2) I land my UAS prior to manufacturer recommended minimum level of battery power 

3) I pilot my UAS through remote control by line of sight 

4) My UAS uses GPS and a flight safety feature whereby it returns to a preprogrammed 

position and then slowly lands if communication with the remote control pilot is lost. 

5) I actively analyze flight data and other sources of information to constantly update 

and enhance safety protocol. 

6) I conduct extensive pre-flight inspections and protocol, during which safety carries 

primary importance. 

7) I always obtain all necessary permissions prior to operation; and, 

8) I have procedures in place to abort flights in the event of safety breaches or potential 

danger. 

Public Interest 

The use of an UAS in the real estate industry provides both buyers and sellers a higher 

level of service. For a buyer a higher level of marketing and advertising is achieved, 

appealing to more buyers, resulting in a quicker sale of their home. Quicker home sales 

also helps accelerate the economy as a whole. Buyers experience the benefit of 

encompassing a whole property, sometimes several acres, in one photo or a short 

video. Not only does this benefit the specific home seller or home buyer, but it benefits 

the general public because it is much more efficient than traditional ways of using a 

plane or helicopter to achieve the same result. We can now provide this level of service 

while being conservative with fuel, time, emissions, noise, and other resources. 

Considering size, weight, speed, and absence of combustible fuels, my UAS will have 

much less of a safety concern for the general public when compared to larger manned 

aircraft. 

Thank you for your consideration. 

Trevor Battieste 
Page 1 of2 

PH T VI ION+ 

Checklist 

Pre-Flight Post-Flight 

1 . Charge flight battery 1 . Turn OFF video recording 

2. Charge range extender 2. Power OFF flight battery 

3. Charge smartphone/tablet 3. Power OFF remote controller 

4. Check/replace remote controller 4. Power OFF range extender 

batteries ( 4 AA) 5. Power OFF smartphone or tablet 

5. Check/adjust props & anti-drop kit 6. Replace gimbal clamp and lens cap 

6. Remove lens cap and gimbal clamp 

7. Insert/reformat Micro-SO card 

8. Set Sl and S2 switches to UP position 

9. Move antenna to vertical position 

1 0. Power remote controller 

11 . Power flight battery. 

12. Power range extender 

13. Power ON smartphone or tablet and 

link to aircraft (DJI VISION App) 

14. Check gimbal and camera angle 

15. Calibrate compass (toggle Sl switch 

6 times and rotate quadcopter 360° 

horizontally and vertically) 

16. Check rear LED flight indicators 

1 7. Check 6+ satellites (DJI VISION App) 

18. Scan flight environment 

Rear LED Fright Indicators Normal 

Front 

Rear 

•• ~1o •• (i,: (Red, Green, Yellcrw flashing in 

Power On S..lf· T e:i.l 

RTF 

Non-GPS 

Lost 

Low 

Battery 

Critical 

Battery 

Sensor Bias 

ti,Jfrl) 

• !'ili: • • ;'~§ • (Green, Yellow flashing in tu<n) 

•• II •• (Slow Green llashinl;J) 

fi:o!; ~jl f~• ('¢! <1~ (Slow Y el~ow f!~shing) 

Rear LED F!ight I ndlc:ators 

::;~· (Quick YeHow flashing) 

• • • • • (Slow Red flashing) 

•• •• • • (Quid< Red ffashing) 

• • • (Thtn Reel flashing off ~1\d O·n) 

Warming Up 

Ready to Fly 

Ready to Fly (nor;·GPS) 

Abnormal 

Re,..,.,le CC<'ltrol!er Signal 

Lo-st 

Low Battery Level 

W<>rning 

Critical Low Battery LeV<!t 

W<lrning 

Not Stationary or Sensor 

Bias is too big 

file :I I I C :IU serslport _residentiDownloads/V isi on %20Checklist.j pg 

Notes 

Aircr<>ft ca•mot take off. 

More than 6 GF>S s<>tellites found. 

Leso than 6 GPS satellites found. 

Notes 

failsafe Fl.lllction will activate. 

DJI VISION App will also show 

warning mess.age-M 

DJI VISlON App wili snow warning 

me:s.s!lge. 

Keep air<::ralt stationary or perform 

IMU calibrat.ior\, 

fi]30% 

[jJ 15% 

5/1812015 
Phantom 2 Vision + 

Mission Checklists 

psFiig __ htorg 

e. 3-coa Arrival CheckUst · ·I 

1. If day and operating out of back of 

vehicle, point vehicle into sun. 

2. Remove case and place on level surface_ 

3. Check distance to nearest airport and/or 

controlled airspace using smartphone or 

tablet app. 

4. If required, use VHF aviation transceiver, 

to contact tower of field if closer than 5 

NM. 

5. Inform tower I CTAF of UAS ops, location, 

and max height of flight 

2. Router - On 

3. Transmitter- On 

4. Toggle Switches - Full Up 

5. Video Monitor - On 

6. Remove UAS from case. 

7. Gimbal Lock & lens Cap- Removed 

8. Micro-SO card- Inserted. 

9. UAS Battery- Inserted 

10. Place UAS in clear and safe launch and 

recovery position if it returns to home. 

11. UAS Battery- On 

12. Wifi Connection to Monitor - Verified 

13. OJI Application- Load 

14. DJI application- Connect to Camera 

15. SO Card - Format 

16. Camera - Full Up 

17. Satellite Connections- Verified 

18. Charge levels- Safe for Flight 

19. Video Recording- Start 

20.Takeoff 

file:///C:/U sers/port _resident/Downloads/DJI -Checklist 1.jpg 

Page 1 of 1 

n.rnvti'Tli'Jit<:>IH ten feet above the 

ground to confirm UAS is under controL 

2. All sticks operate correctly while in hover 

-Verified 

2. Video Recorder- Stop 

3. landing Zone - Clear I Safe 

1. Battery - Remove & Replace 

2. Wifi Connection to Monitor- Verified 

3. DJI application- Connect to Camera 

4. Takeoff 

End of Ops Checklist 

1 _ Battery - Off 

2. Transmitter- Off 

3. Router- Off 

4. Notify Tower/CTAF - End of Ops 

5/18/2015