Strategic Propei1J Solutions 

October 18, 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 

Dear Sir /Madam: 

This petition is being submitted pursuant to Section 333 of the FAA Modernization 

and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11. Strategic Property 

Solutions, LLC, a Georgia based limited liability company operating a Small 

Unmanned Aircraft System (sUAS) equipped to conduct aerial imagery data 

acquisition for various industries, hereby applies for an exemption from Federal 

Aviation Regulations (FARs) listed below to allow operation of our sUAS 

commercially in airspace regulated by the Federal Aviation Administration (FAA) so 

long as such operations are conducted with and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333. 

The requested exemption would permit Strategic Property Solutions, LLC to pursue 

its commercial interest in providing services to consumers interested in data 

acquisition by aerial imagery using a sUAS in the following markets: 

• Property Inspection 

• Photography for real estate advertising 

The ability to provide these services to other local businesses and individuals 

in my community will benefit them by opening up opportunities they 

otherwise did not have before. Traditional methods of aerial 

photography jvideography are simply not viable options for the average 

consumer as they are costly and involve greater risks to everyone 

involved; i.e. the use of larger aircraft carrying humans and flammable fuel. By 

utilizing the UAV /UAS the same results can be achieved with much safer 

conditions. 

Prior to each flight/operation of the UAV /UAS, we will conduct a Pre-Flight 

Safety Inspection as required. See Exhibit A for pre-flight safety checklist. 
Strategic Property Solutions, LLC states that all sUAS flights will occur over private 

or controlled access property and will only do so with the property owner's prior 

consent and knowledge and not before a thorough inspection of the property. 

Strategic Property Solutions, LLC sUAS operators will be required to: 

• Be at least 21 years old and have a current United States passport and drivers 

licenses and a minimum of a Pilot Private License see Exhibit B. 

• Pass the written FAA approved aeronautical knowledge test 

• Obtain a Letter of Qualification by the Company 

• Conduct a preflight inspection, which includes specific aircraft, and control station 

systems check. 

• Have a minimum of 25 hours of in field training 

• Have current medical and be of sound mental health see Exhibit C. 

Strategic Property Solutions, LLC will have the following Operational Limitations: 

• Unmanned aircraft will weigh less than 55 Lbs. 

• The unmanned aircraft will remain within visual line-of-sight of the operator or 

visual observer 

• Unmanned aircraft will not operate over any person not directly involved in the 

operations 

• Daylight-only operations 

• Must yield right-of-way to all other aircraft 

• Maximum airspeed of 25 mph 

• Maximum altitude of 400 feet above ground level 

• Minimum weather visibility of 3 miles from control station 

• Operations are limited to Class G airspace 

Strategic Property Solutions, LLC is seeking relief from FAA airworthiness 

certification aircraft, however all aircraft will be registered with the FAA and N 

number displayed in the largest practicable manner. 

Strategic Property Solutions, LLC is requesting exemption from the following 

regulations: 

• 14 C.F.R. Part 21 

• 14 C.F.R. 45.23 (b) 

• 14 C.F.R. 61.11 (a) and (b) 

• 14 C.F.R. 91.7 (a) 

• 14 C.F.R. 91.9 (b) (2) 

• 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. 205 (b) 

• 14 C.F.R. 91.215 

• 14 C.F.R. (91.401- 91.417) 

Strategic Property Solutions, LLC understands that if a C.F.R. is not specifically listed 

in the exemptions given by the FAA we will comply with it. 
Strategic Property Solutions, LLC will be conducting operations with two types and 

models of aircraft. All operation limitations list above will apply to both aircraft. 

Both aircraft are multi-rotor, Cheerson CX-20 and DJI Phantom 3. Both models will 

be equipped with the Autopilot System for aerial imagery mapping. Each model will 

be operated by it's own controller using the standard 2.400 GHz-2.483 GHz. Both 

drones are equipped with three major safety items: 1. Return to Home switch 2. 

Land immediately switch and 3. GeoFencing- used to set flight boundaries. See 

Exhibits D and E. 

Strategic Property Solutions, LLC respectfully request exemption under Section 333 

to enable us to operate safe, low risk commercial sUAS operations for the activities 

stated. Strategic Property Solutions, LLC will at all times respect the space and 

privacy of citizens and property while maintaining safe skies. 
Exhibit A 

• VeriJYin2 all transmitter, on-board aircraft and camera batteries are fully char~~Cd; (confirm volta2es) 

Ensure no frequency conflicts with both video and transmitter I receiver 

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Checkin2 all control surfaces for silllls of dama2e, loose hin2es, and overall condition; Lookin2 over the win2/rotors to 

ensure they are in 20od structural condition and properly secured; 

Check motor/enlline and mountin2 attached to the airframe; 

Stndy propellers I mountin2 hardware (ti2ht) I rotor blades for chips and deformation; 

Check the landin2 2ear for dama2e and function 

Test electrical connections, plu22ed in and secure 

Ensure photo I video equipment mountin2 system is secure and operationaL 

Check location of GPS equipment controllin2 the autopilot . 

Check the IMU movements in the 2round control software . 

UA V in stabilization mode, ensure control surfaces move towards the correct positions 

UA VI Drone is in a level location safe for takeoff 

FPV I Power up 2round station 

FPV I Power up Video receiver I 2022Ies 

If usin2 Video recorder tnru on camera system 

Camera settilllls are correct (still ima2es, video, framerate) 

SD camera memory clear and inserted into the camera 

All transmitter controls move freely in all directions 

All transmitter trims in neutral position 

All transmitter switches in correct position( typically away) 

Transmitter throttle to zero 

Radio transmitter on 

Connect I power on battery to airframe 

Ensure led indicators and audible tones are correct 

FPV, confirm video is in monitor I2022Ies 

Scan for nearby cars I people I animals 

Say "CLEAR!" 

Arm ffi2ht controller 

Increase throttle sli2htly listenin2 for any abnormalities 

Short 20-30 second hover at 3-5 feet (listen for vibrations /loose items) 

Confirm Voltage levels are correct 
Exhibit B 
UNITED STATES OF AMERICA 

Department of Transportation 

Federal Aviation Administration 

MEDICAL CERTIFICATE THIRD CLASS 

This certifies that (Full name and address): 

MATTHEW OUDEKERK 

975 Julius Drive 

Suwanee GA 30024 USA 

Date of Birth ! Height Weight i Hair , Eyes Sex 

- o7/17/r967_1 _ -73 , -- 21 o -;-·-BALD --~ BLUE M 

has met the medi~~l sta~d~;.ds prescribed in p~rt 67--:f;;deral Aviation 

Regulations, for this class of Medical Certificate. 

! None I 

§ I +i t s · . E 

:::i 

... 

Gl 

c .E 

tO 

>< w 

Control No.: 200007066648 

FAA Form 8500~9 (3~ 12} Supersedes Previous Edition 

CONDITIONS OF ISSUE 

The holder of this certificate must: 

• Have it in his or her personal possession at all times 

while exercising privileges of an airman certificate. 

(14CFR § 61.3) 

• Understand that the issuance of a medical certificate 

by an Aviation Medical Examiner may be reversed by the 

FAA within 60 days. 

(14CFR § 67.407) 

• Comply with validity standards specified for first-, 

second-, and third-class medical certificates. 

(14CFR § 61.23) 

• Comply with any statement of functional, operational, 

and/or time limitation issued as a condition of 

certification. 

(14CFR § 67.401) 

• Comply with the standards relating to prohibitions on 

operation during medical deficiency . 

(14CFR §§ 61.53, 63.19, and 65.49) 

For International Operations Only: Some holders may be 

affected by certain international medical standards. 

Consult the U.S. Aeronautical Information Publication for 

U.S. differences with ICAO Annex 1 medical standards . 
Cheerson CX-20 Specs 

Physical Attributes 

Dimensions 

Body Material 

Rotor Material 

Available Colors 

Size and Color 

Wingspan 509 mm 

Weight 980 grams 

Exhibit 0 

360x 

360x 

200mm 

Plastic 

Carbon 

Fiber 

White 

With a wingspan of 509 mm, or 20.0 inches, this drone is about average in 

size. The CX-20 is of average weight for a drone, weighing in at 980 grams 

or 2.2 pounds. As far as color goes, it is only available in white. 
 Phantom 3 Specs Professional & Advanced 

ht (Including Battery And Propellers): 

 

nal Size (Including Propellers): 

m 

Ascent Speed: 

Descent Speed: 

r Accuracy: 

al: +1- 10cm 

tal: +1- 1m 

peed: 

 (AITI mode, no wind) 

ltitude Above Sea Level: 

m 

ating Temperature: 

40°C 

Mode: 

GLONASS 

or: 

XMOR 1/2.3" Effective pixels: 12.4 M (total pixels: 12.76 M) 

4° 20 mm (35 rom format equivalent) f/2.8, focus at oo 

ange: 

00 (video) 100-1600 (photo) 

er Speed: 

000s 

 Max Size: 

3000 

hotography Modes: 

Shot 

hooting: 31517 shots 

xposure Bracketing (AEB): 3/5 
eted Frames at 0.7EV Bias 

apse 

 Recording Modes 

om 3 Professional: 

4096x2160p 24/25, 3840x2160p 24/25/30 

1920x1080p 24/25/30/48/50/60 

280x720p 24/25/30/48/50/60 

om 3 Advanced: 

1920xl080p 24/25/30/48/50/60 

280x720p 24/25/30/48/50/60 

orted SO Card Types: 

SD 

apacity: 64GB. Class 10 or UHS-1 rating required 

Bitrate Of Video Storage: 

ps 

orted File Formats: 

/exFAT 

JPEG, DNG 

 MP4, MOV (MPEG-4 A VC/H.264) 

ating Temperature: 

40°C 

ollable Range: 

90° to +30° 

ization: 

(pitch, roll, yaw) 

elocity: 

an 8 m/s (when 2m above ground) 

de Range: 

300cm 

ating Range: 

300cm 

ting Environment: 

e with clear pattern and adequate lighting (Lux > 15) 

ting Frequency: 

GHz-2.483 GHz 

Distance: 

 (outdoors and unobstructed) 

 Output Port: 
ating Temperature: 

0°C 

ry: 

mAh LiPo 2S 

e Device Holder: 

let or phone 

ver Sensitivity (1%PER): 

Bm ±2 dBm 

mitter Power (EIRP): 

20dBm 

6dBm 

Voltage: 

@7.4 V 

ge: 

 

 Power 

om 3 Professional: 

 

om 3 Advanced: 

city: 

mAh 

ge: 

 

ry Type: 

S 

y: 

 

eight: 

light Time: 

ximately 23 minutes 

ating Temperature: 

to 40°C 

Charging Power: 

 

e App: 

ot 

 
W 

View Working Frequency: 

HziSM 

View Quality: 

@ 30fps (depending on conditions and mobile device) 

cy: 

 (depending on conditions and mobile device) 

red Operating Systems: 

0 or later 

id 4.1.2 or later 

mmended Devices: 

Phone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi +Cellular, iPad mini 2, iPad mini 2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi 

ular, iPad mini 3, and iPad mini 3 Wi-Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus 

d: Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 mini 

ort for additional Android devices available as testin~:r and development continues