Pharr Properties-2508 Cima Hill Dr

Plano TX 75025 Tele: (214)707-6154

May 29, 2015 

U. S. Department of Transportation Docket 

Management System 1200 New Jersey Ave, 

SE Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA 

Reform Act of the Federal Aviation Regulations 

from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 

91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 

91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 

91.409(a) (2); 91.417(a)&(b) 

Dear Sir or Madam, 

We, Pharr Properties, are writing pursuant to 

the FAA Modernization and Reform Act 

of 2012 and the procedures contained within 

14 C.F.R. 11, to request that Westside 

Drones, an owner and operator of small 

unmanned aircraft, be exempted from the 

Federal Aviation Regulations (“FARs”) listed 

below so that We, Westside Drones, may 

operate our small ultra light weight unmanned

aircraft system (“UAS”) commercially in 
airspace regulated by the Federal Aviation 

Administration (“FAA”). 

As described herein Pharr Properties

Members, are Certified Private Pilots in the 

United States; experienced in flying hobby 

Quad Copters for recreational purposes. Our 

Inventory includes a one DJI Phantom 3 with 

4k camera with the intent for aerial 

videography/cinematography to enhance 

academic community 

awareness for those individuals and 

companies unfamiliar with the geographical 

layout of the Southern California area, and 

augment real estate listing videos; following 

exemption and approval by the FAA. Thereby 

enhancing their academic research 

experience for the Southern California area. 

UAS Specs Below: 

Phantom 3 AircraftWeight (Including Battery And Propellers) 

1280 g 

Diagonal Size (Including Propellers) 

590 mm 
Max Ascent Speed 

5 m/s 

Max Descent Speed 

3 m/s 

Hover Accuracy 

• Vertical: +/- 10cm 

• Horizontal: +/- 1m Max Speed 16 m/s (ATTI mode, no 

wind) Max Altitude Above Sea Level 6000 

m Operating Temperature 0°C to 40°C Gps 

Mode GPS/GLONASS 3DR Solo Smart Drone 

Aircraft- Cameras: Compatible with 

GoPro® HERO3, 3+ and 4; optimized 

for HERO3+ and 4 

Streaming video quality: 4K

Flight time: 25 minutes; 20 minutes with 

payload* 

Range: .5 miles** (.8 km) 

Max speed: 55 mph (89 km/h) 

Max ascent speed: 10 m/s in stabilize mode; 

“fly” mode spec forthcoming 
Max descent speed: ditto 

Max payload: 420 g 

Max altitude: 400 ft per FAA regulation, 

user adjustable (122 m) 

Motors: 880 kV 

Propellers: 10ʺʺ diameter 4.5ʺʺ pitch selftightening (24 cm diameter 144 cm pitch) 

Autopilot: Pixhawk 2 

Software: APM:Copter 

Communication: 3DR Link secure WiFi 

network 

Frequency: 2.4 GHz 

Weight: 3.3 lbs. (1.5 kg) / 3.9 lbs. (1.8 kg) 

with GoPro® and Solo Gimbal 

Dimensions: 10 in. tall (25 cm), 18 in. (46 

cm) motor-to-motor Flight battery: Lithium 

polymer 5200 mAh 14.8 Vdc 

Battery charge time: ~1.5 hoursController 
battery: 2600 mAh 7.2 Vdc rechargeable 

lithium ion 

Pharr Properties is Committed to safety with 

each flight. Pharr Properties exemption 

request would permit operation of ultra light 

weight, unmanned (piloted by remote control) 

and comparatively inexpensive UAS(s) in 

tightly controlled and limited 

airspace. Predetermined in areas away from 

general public, airports, heliports and 

vehicular traffic for community videos, and 

within property boundaries for individual 

homeowner real estate listing videos/photos. 

Granting our, Pharr Properties, request 

comports with the Secretary of 

Transportation’s (FAA Administrator’s) 

responsibilities and authority to not only 

integrate UAS's into the national airspace 

system, but to “...establish requirements for 

the safe operation of such aircraft systems 

[UAS's] in the national airspace system” under 

Section 333(c) of the Reform Act specific to 

the use of UAS's for real estate/Realtor 

purposes. Further We, Pharr Properties, will 

conduct our operations in compliance with the 
protocols described herein or as otherwise 

established by the FAA. 

For the reasons stated below, We, Pharr 

Properties, respectfully request the grant of an 

exemption allowing us to operate ultra light 

weight, remote controlled UAS’s for academic 

community awareness to benefit/stimulate 

attraction to the Dallas area and to enhance 

real estate listing videos for homeowners who 

cannot afford expensive manned aircraft for 

the same purpose. Both of which will promote 

local economic growth through increased 

employment and increased tax base. Both 

with public safety in mind by keeping heavier 

manned aircraft containing combustible fuel 

that poses potential public hazard. 

I. Contact Information: 

Pharr Properties, Jonathan Pharr 2508 

Colborne DR Plano TX 75025 Tele:(214) 707-

6154 Email: jonathan@pharrproperties.com

II. The Specific Sections of Title 14 of the 

Code of Federal Regulations from which 

Pharr Properties, Requests Exemption 

are: 
14 CFR 21; 14 C.F.R. 45.23(b); 14 C.F.R. 91, et 

seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); 

and, 14 CFR 417 (a) & (b). 

III. The Extent of relief Pharr Properties

seeks and the Reason We Seek Such 

Relief: 

We, Pharr Properties, submit this application 

in accordance with the Reform Act, 112 P.L. 

95 §§ 331-334, seeking relief from any 

currently applicable FARs operating to prevent 

we, Pharr Properties, contemplated 

commercial cinematic, academic and other 

flight operations within the national airspace 

system. The Reform Act in Section 332 

provides for such integration of civil 

unmanned aircraft systems into our national 

airspace system as it is in the public’s interest 

to do so. Our, Pharr Properties, ultra light 

weight UAS meets the definition of “small 

unmanned aircraft” as defined in Section 331 

and therefore the integration of our ultra light 

weight UAS is expressly contemplated by the 

Reform Act. We would like to operate our light 

weight UAS prior to the time period by which 

the Reform Act requires the FAA to 
promulgate rules governing such craft. 

Thereby, providing direct experience and 

valuable information for formal regulation that 

can be administered uniformly to all real 

estate related UAS aerial video 

and photography. The Reform Act guides the 

Secretary in determining the types of UAS's 

that may operate safely in our national 

airspace system. Considerations include: The 

weight, size, speed and overall capabilities of 

the UAS's; Whether the UAS will be operated 

near airports or heavily populated areas; and, 

Whether the UAS will be operated by line of 

sight. 112 P.L. 95 § 333 (a). Each of these 

items reflect in favor of an exemption for us, 

Pharr Properties. Our UAS utilizes eight (4) 

counter- rotating propellers for balance, 

control and stability. Our UAS is equipped with 

GPS and auto return safety technology. 

Weighing less than fifteen (20) pounds (far 

below the max. 55 pound limit); including 

camera with gimbal. 

Pharr Properties, considers safety as foremost 

with each flight. Our small unmanned 

aircraft is designed to hover in place via GPS 
and operate in less than a 13 knot (15 mph) 

wind. For safety, stability and fear of financial 

loss we will not fly in winds exceeding 

13 knot (15 mph). Built in safety systems 

include a GPS mode that allows our UAS to 

hover in place when radio controls are 

released. No UAS operations near airports, 

Hospitals nor Police heliports, and do not 

operate near areas where general public is 

within fifty to one hundred (50-100) yards 

depending on location, conditions and 

weather. We are constantly on alert for any 

manned aircraft (Police/Medical helicopters, 

etc.) and prepared to land/abort immediately 

to the nearest and safest ground point should 

a manned aircraft approach our location or we 

suspect manned aircraft may approach near 

our location. Our UAS is capable of vertical 

and horizontal operations, and are flown only 

within our line of sight of us, as the remote 

control pilot. Utilizing battery power rather 

than combustible fuels, flights generally last 

between ten (10) to fifteen (15) minutes, with 

an altitude under three hundred (300) feet. 

We, Westside Drones, utilize a fresh fully 

charged battery with each flight as a safety 
precaution; full flight time limit for each battery 

is ten (10) to fifteen (15) minutes as tested. 

We do not operate our UAS at or below 

manufacture recommend minimum charge 

levels for operation; preferring to 

remain well within a safe operating range to 

insure adequate communication between 

radio control and UAS to eliminate potential 

for crash, loss of control or hazard. Reserve 

batteries are at hand with each exercise to 

insure replacement for sufficient safe level of 

operation. We do not believe in taking risk that 

may cause a crash, that could create hazard 

to the public/property/ manned aircraft, and 

have no desire to lose an investment. We 

have clocked numerous practice flights in 

remote areas as a hobbyist simulating flights 

for future commercial use to gain 

familiarization with the characteristics of this 

specific UAS's performance under different 

temperature and weather conditions. 

We, Pharr Properties, are extremely cautious 

when operating our UAS/ultra light weight 

unmanned aircraft and will not “create a 

hazard to users of the national airspace 
system or the public.” 112 P.L. 95 § 333 (b). 

Given the small size and weight of our UAS it 

falls well within Congress’s contemplated 

safety zone when it promulgated the Reform 

Act and the corresponding directive to 

integrate UAS's into the national airspace 

system. Westside Drones UAS, used in hobby 

flight, has a demonstrable safety record and 

does not pose any threat to the general public 

or national security. 

IV. How Pharr Properties Request Will 

Benefit the Public As A Whole: 

Aerial videography for geographical 

awareness and for real estate marketing has 

been around for a long time through manned 

fixed wing aircraft and helicopters. For small 

budget real estate companies and average 

homeowners the expense of such aerial 

videography is cost prohibitive. Only large 

companies and high end Realtors or luxury 

homeowners can afford to absorb such 

expense. Depriving non-luxury homeowners 

and lower budget Realtors from a valuable 

marketing tool. Manned aircraft pose a threat 

to the public through potential catastrophic 
crash that the Dallas community has 

experienced in the past with military aircraft 

and medical helicopter crashes within the 

SoCal area. 

Each resulting in loss of life. Each with 

combustible fuel that exploded and burned on 

impact. Police helicopters have made 

emergency hard landings within city limits. 

Our, Pharr Properties, UAS pose no such 

threat since size and lack of combustible fuel 

alleviates any potential threat to the public. 

Congress has already proclaimed that it is in 

the public’s interest to integrate commercially 

flown UAS's into the national airspace system, 

hence the passing of the Reform Act. Granting 

Our, Pharr Properties, exemption request 

furthers the public interest through 

academic/visual awareness of the 

geographical benefits in and around the 

Dallas area. Our ultra light weight UAS is 

battery powered and creates no emissions 

that can harm the environment. The 

consequence of my ultra light weight UAS 

crashing is far less than a full size helicopter 

or fixed wing aircraft; which are heavy, contain 
combustible fuel and can cause catastrophic 

devastation to the public.The public’s interest 

is furthered by minimizing ecological and 

crash threat by permitting aerial video/photo 

capture through our battery operated ultra 

light weight UAS's. Permitting us,Pharr 

Properties, to immediately fly within national 

air space furthers economic growth. Granting 

our exemption request substantially furthers 

the economic impact for the Los Angeles 

community for companies looking to relocate 

or build in the SoCal area as well as 

individuals looking to relocate for career 

advancement through academic and 

geographical awareness. Both of which serve 

as a stimulus to the community. 

V. Reasons Why Pharr Properties

Exemption Will Not Adversely Affect 

Safety Or How The Exemption Will 

Provide a Level of Safety At Least Equal 

To Existing Rule: 

Our, Pharr Properties, exemption will not 

adversely affect safety. Quite the contrary, for 

the reasons stated permitting us, Westside 

Drones, to log more flight time in FAA 
controlled airspace, with communication with 

the FAA, will allow us to contribute to the 

innovation and implementation of new and 

novel, as of yet 

undiscovered safety protocols for Realtors 

that can be embraced by the National 

Association of Realtors and Texas Association 

of Realtors, for development in cooperation 

with the FAA. In addition We, Pharr 

Properties, submit the following 

representations of enhancements to current 

aerial videography and photography for real 

estate: 

Our UAS weighs less than 20 pounds 

complete with gimbal and high resolution 

Cameras; We only operate our UAS below 

300 feet (well within the 400 foot permissible 

ceiling set by the FAA Modernization and 

Reform Act of 2012); 

Our UAS only operate for 10-15 minutes per 

flight; We land our UAS prior to manufacturer 

recommended minimum level of battery 

power; We pilot our UAS through remote 

control only by line of sight; Our UAS has 

GPS a flight safety feature whereby it hovers 
and then slowly lands if communication with 

the remote control pilot is lost; We actively 

analyze flight data and other sources of 

information to constantly update and enhance 

safety protocols; We only operate in 

reasonably safe environment that are strictly 

controlled, are away from power lines, 

elevated lights, airports and actively populated 

areas; We conduct extensive pre-flight 

inspections and protocol, during which safety 

carries primary importance; and We always 

obtain all necessary permissions prior to 

operation. 

Our, Pharr Properties, safety protocols 

provide a level of safety equal to or exceeding 

existing rules. It is important to note that 

absent the integration of commercial UAS into 

our national airspace system, helicopters are 

the primary means of aerial video and 

photography for community awareness and 

real estate. While the safety record of such 

helicopters is remarkably astounding, there 

has been local incident involving loss of life as 

well as extensive property damage; it is far 

safer to operate a 
battery powered ultra light weight UAS. 

First, the potential loss of life is diminished 

because UAS's carry no people on board and 

we only operate our UAS in specific areas 

away from mass populations. 

Second, there is no fuel on board a UAS and 

thus the potential for fire or explosions is 

greatly diminished. 

Third, the small size and extreme 

maneuverability of our UAS allows us to 

remotely pilot away from and avoid hazards 

quickly and safely. 

Lastly, given its small size and weight, even 

when close enough to capture amazing 

images, our UAS need not be so close to the 

objects they are focused on through the 

technology and use of post editing software 

allowing pan and zoom. 

Accordingly, our UAS has been 

experimentally operated for 

familiarization/competency and will continue to 

operate at and above current safety levels. 

VI. A Summary The FAA May Publish in 
the Federal Register: 

A. 14 C.F.R. 21 and 14 C.F.R. 91: 

Airworthiness Certificates, Manuals and The 

Like. 

14 C.F.R. 21, Subpart H, entitled 

Airworthiness Certificates, sets forth 

requirements for procurement of necessary 

airworthiness certificates in relation to FAR § 

91.203(a)(1). The size, weight and enclosed 

operational area of our, Pharr Properties, UAS 

permits exemption from Part 21 because our 

UAS meets (and exceeds) 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 

UAS's from the airworthiness certificate 

requirement in consideration of the weight, 

size, speed, maneuverability and proximity to 

areas such as airports and dense populations. 

Our, Westside Drones, current and projected 

UAS's meet or exceed each of the elements. 
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. § 91.9 (b) (2) requires an aircraft 

flight manual in the aircraft. As there are no on 

board pilots or passengers, and given the size 

of the UAS's, this Regulation is inapplicable. 

An equivalent level of safety will be achieved 

by maintaining our, 

Pharr Properties, safety protocols. The FAA 

has previously issued exemptions to this 

regulation in Exemption Nos. 8607, 8737, 

8738, 9299, 9299A, 9565, 9565B, 10167, 

10167A, 10602, 10700 and 32827. 

14 C.F.R. § 91.121 regarding altimeter settings 

is inapplicable insofar as our UAS utilizes 

electronic global positioning systems with a 

barometric sensor. 

14 C.F.R. § 91.203 (a) and (b) provides for the 

carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same 

reasons described above. The equivalent level 

of safety will be achieved by maintaining any 
such required certifications and registrations by 

us, Westside Drones. 

14 C.F.R. § 45.23: Marking of The Aircraft. 

Applicable Codes of Federal Regulation require 

aircraft to be marked according to certain 

specifications. Our UAS are, by definition, 

unmanned. They therefore do not have a cabin, 

cockpit or pilot station on which to mark certain 

words or phrases. Further, two-inch lettering is 

difficult to place on such small aircraft with 

dimensions smaller that minimal lettering 

requirement. Regardless, We will mark our UAS 

in the largest possible lettering by placing the 

word “EXPERIMENTAL” 

on its fuselage as required by 14 C.F.R. §45.29 

(f) so that we the pilot, or anyone assisting me 

as a spotter with the UAV will see the markings. 

The FAA has previously issued exemptions to 

this regulation through Exemptions Nos. 8738, 

10167, 10167A and 10700. 

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

14 C.F.R. § 91.119 prescribes safe altitudes for 

the operation of civil aircraft. It allows helicopters 

to be operated at lower altitudes in certain 

conditions. Our UAS will never operate at an 
altitude greater than 300 AGL; safely below the 

standard of 400 AGL. We, Pharr Properties, will 

however operate our UAS in safe areas away 

from public and traffic, providing a level of safety 

at least equivalent to or below those in relation 

to minimum safe altitudes. Given the size, 

weight, maneuverability and speed of our UAS, 

an equivalent or higher level of safety will be 

achieved. 

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 

417(a) & (b): Maintenance Inspections. 

The above-cited Regulations require, amongst 

other things, aircraft owners and operators to 

“have [the] aircraft inspected as prescribed in 

subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) 

of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter. . . .” 

These Regulations only apply to aircraft with an 

airworthiness certificate. They will not, therefore, 

apply to our, Westside Drones,UAS. However, 

as a safety precaution we inspect our UAS 

before and after each flight as well as 

maintaining a maintenance log. 

A Summary The FAA May Publish in the 
Federal Register: 

A. 14 C.F.R. 21 and 14 C.F.R. 91: 

Airworthiness Certificates, Manuals and The 

Like. 14 C.F.R. 21, Subpart H, entitled 

Airworthiness Certificates, sets forth 

requirements for procurement of necessary 

airworthiness certificates in relation to FAR § 

91.203(a)(1). The size, weight and enclosed 

operational area of our UAS permits 

exemption from Part 21 because our, 

Westside Drones, UAS 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 UAS's 

from the airworthiness certificate requirement 

in consideration of the weight, size, speed, 

maneuverability and proximity to areas such 

as airports and dense populations. Our UAS 

meets or exceeds each of the elements. 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. § 91.9 

(b) (2) requires an aircraft flight manual in the 

aircraft. As there are no pilots or passengers, 

and given the size of the UAS's, this 

Regulation is inapplicable. An equivalent level 

of safety will be achieved by maintaining a 

manual. The FAA has previously issued 

exemptions to this regulation in Exemption 

Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 

9565B, 10167, maintenance program that 

involves regular software updates and 

curative measures for any damaged 

hardware. Therefore, an equivalent level of 

safety will be achieved. 

In summary, Pharr Properties seeks an 

exemption from the following 

Regulations: 

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 

14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 

14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 

C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 

C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) 

and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 
91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 

C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 

91.417 (a) & (b) to commercially operate our, 

Pharr Properties, small unmanned 

vehicle/lightweight unmanned aircraft vehicle 

in community awareness and real estate 

operations, and to develop economic 

platforms for real estate to enhance the 

experience of those seeking to relocate to the 

Los Angeles area. Currently, area awareness 

and real estate aerial 

videography/photography relies primarily on 

the use of 

larger aircraft running on combustible fuel. 

Posing potential risk to the public. Granting 

our, Westside Drones, request for exemption 

will reduce current risk levels and thereby 

enhance safety. Our UAS craft do not contain 

potentially explosive fuel, is smaller, lighter 

and more maneuverable than conventional 

real estate video and photographic aircraft 

with less flight time. Further, We operate at 

lower altitudes and in controlled airspace 

eliminating potential public risk flying to and 

from established air fields. We, Westside 

Drones have been informally analyzing flight 
information and will compile safety protocols 

and the implementation of a flight operations 

manual for real estate usage that exceeds 

currently accepted means and methods for 

safe flight. Formal collection of information 

shared with the FAA will enhance the FAA's 

internal efforts to establish protocols for 

complying with the FAA Modernization and 

Reform Act of 2012. There are no personnel 

on board our, Pharr Properties, UAS and 

therefore the likelihood of death or serious 

bodily injury is significantly diminished. our, 

Pharr Properties, operation of our UAS, 

weighing less than 20 pounds and traveling at 

lower speeds within limited areas will provide 

an equivalent level of safety as that achieved 

under current FARs. Accordingly We, Pharr 

Properties, respectfully request that the FAA 

grant our exemption request and are willing 

to cooperate in sharing information to benefit 

the FAA, safety of manned aircraft, and the 

general public at large. 

Respectfully submitted, 

Pharr Properties-2508 Cima Hill DR Plano, TX 

75025