May 17, 2015 U. S. Department ofTransportation Docket Management System 1200 NewJerseyAve., Washington, DC 20590

RE: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations. Dear Sir 

### I Madam: Pursuantto the Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act"), Trevor Battieste (the "applicant"), operator ofan Unmanned Aircraft Systems ("UAS") seeks an exemption from the Federal Aviation Regulations ("FARs") to allowfor commercial operation for aerial imaging and video of homes 

### &properties applicant listfor sale in the Dallas, Ft. Worth (DFW) area. Applicant: Trevor Battieste 11601 Lago Vista #1205 Farmers Branch, Texas 75234
Attachments: DJI PilotTraining 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 HThe UAS to be operated carries neither pilot nor passenger and carries no explosive materials orflammable liquids. Given the size, weight, speed, and limited operating area associated with the aircraftto be utilized, I request exception. In the restricted environment and underthe 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 ofthis UAS it does not have a cockpit, cabin, or pilot station on which to market certain words or phrases. Lettering would be very difficultto place on such a small aircraft and dimensions would need to be smallerthan required minimum. Understanding the importance of lettering. Iwill mark my UAS with the largest possible letters by placing the word "Experimental" or assigned numberor name, based on request/ruling of FAA, on UASfuselage. The equivalent level ofsafety 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 existfor determining airworthiness. Given the size ofthe aircraftfor maintenance and use ofsafety check list priorto each flight an equivalent level ofsafetywill be provided.
14 CFR 91.9 (b) (2) Given the size and configuration, the UAS has no abilityto carry a flight manual on the aircraft. There is no room, capacity, or pilot on board to adequately carry flight manual. An equivalent level ofsafetywill 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 forthe aircraft, an exemption will be needed. Normal procedures including but not limited to; reviewing weather, flight battery requirement, landing and takeoffdistances, along will all ofthose found in attachment "OJI PilotTraining". An equivalent level ofsafetywill 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 ofa control boxthat communicates with the aircraft via radio communications. The equivalent level ofsafety provided because neither a pilot nor passengerwill be carried in the aircraft, and bythe speed and size ofthe aircraft.14 CFR 91.113 (a) and (b) I can achieve an equivalent level ofsafety 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 ofsafety 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) Similarto, 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 ofsafety will be achieved by keeping these documents, to the extentthey are applicableto the UAS, atthe ground control point where pilot has immediate access to them.

14 CFR 91.405 (a), 14CFR 91.407 (a) (1), 14CFR 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 applyto this applicant. As a safety precaution, operatorwill perform preflight inspections and ensure UAS is in working condition before initiating each flight. Trevor Battieste is seeking relieffrom all FARs above preventing applicantfrom 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 of25 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 ofthe UAS's meets the definition of "small unmanned aircraft" found in section 331 "The Reform Act". In orderto obtain high quality photography and video the UAS will be used at speeds much less than it's top speed of33.5 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, Ifind this exception to be reasonable with an equivalent, or greater, level ofsafety to be reached by the operator.
Safety: *Please see attachment "OJI PilotTraining" for safety precautions I use for every flight. Aside from these practices Iwas given a hands on training course when I purchased my UAS.Additionally: 1) I do not operate within 5 miles ofan airport unless prior contact to AirTraffic Control orthe airport manager has been made. 2) I land my UAS priorto manufacturer recommended minimum level of battery power 3) I pilot my UAS through remote control by line ofsight 4) My UAS uses GPS and a flight safety feature whereby it returns to a preprogrammed position and then slowly lands ifcommunication 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 priorto operation; and, 8) I have procedures in place to abort flights in the event ofsafety breaches or potential danger.

Public Interest The use ofan UAS in the real estate industry provides both buyers and sellers a higher level ofservice. For a buyer a higher level of marketing and advertising is achieved, appealing to more buyers, resulting in a quickersale oftheir 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 efficientthan traditional ways of using a plane or helicopterto achieve the same result. We can now provide this level ofservice while being conservative with fuel, time, emissions, noise, and other resources. Considering size, weight, speed, and absence ofcombustible fuels, my UAS will have much less ofa safety concern for the general publicwhen compared to larger manned aircraft.

Thank you for your consideration. Trevor BattiestePage 1of2 

# PH T VI ION+ 

# Checklist
Pre-Flight Post-Flight 1 . Chargeflight 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 rangeextender batteries ( 4 AA) 5. 

### Power OFF 

### smartphone ortablet 5. 

### Check/adjust props 

### &anti-drop kit 

### 6. Replacegimbal 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 antennatovertical position 1

0. 

### Power remotecontroller 

### 11

. Power flight battery. 

### 12. Power range extender 13. 

### Power ON 

### smartphone or tablet and linkto aircraft (DJI VISION 

### App) 14. 

### Checkgimbal and camera angle 

### 15. Calibrate compass (toggle 

### Sl switch 6 

### times and rotate quadcopter 360° 

### horizontally and vertically) 16. 

### Check rear LED flight 

### indicators 17. 

### 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 OnS..lf·Te:i.l



### RTF Non-GPS



### Lost 

### Low Battery Critical Battery Sensor Bias ti,Jfrl)

• !'ili: • •**;'~§** • (Green, Yellowflashing in tu<n) ••II ••(SlowGreen llashinl;J) fi:o!;**~jl f~•**  ('¢!**<1~** (SlowY**el~ow f!~shing)**  Rear LED F!ight Indlc: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 NotStationaryorSensor Bias is toobig

file:IIIC:IUserslport _residentiDownloads/Vision%20Checklist.jpg Notes

Aircr<>ft ca•mottake off. More than 6GF>S s<>tellites found. Leso than 6 GPS satellites found. Notes

failsafe Fl.lllctionwill activate.

DJI VISION App will also show warning mess.age-M DJI VISlON Appwili 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. Ifday and operating outof back of vehicle, pointvehicle into sun. 2. Remove case and place on level surface_ 3. Check distance to nearestairport and/or controlled airspace usingsmartphone or tablet app. 4. If required, use VHF aviation transceiver, to contacttower offield ifcloserthan 5 NM. 5. Informtower ICTAF of UAS ops, location, and max heightofflight

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 ifit returns to home. 11. UAS Battery- On 12. Wifi Connection to Monitor

- Verified 13. OJI Application- Load 14. DJI application- Connectto 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:/Users/port _resident/Downloads/DJI-Checklist1.jpg Page 1of 1

n.rnvti'Tli'Jit<:>IHten feet above the groundto confirm UAS is under controL 2. All sticks operate correctlywhile in hover -Verified

2. Video Recorder- Stop 3. landing Zone

- ClearI Safe

1. Battery

- Remove & Replace 2. Wifi Connection to Monitor- Verified 3. DJI application- Connectto Camera 4. Takeoff End of Ops Checklist 1 _ Battery

- Off 2. Transmitter- Off 3. Router- Off 4. NotifyTower/CTAF

- End ofOps

5/18/2015