# Strategic Propei1J Solutions

October 18, 2015 U.S. Department ofTransportation Docket Management System 1200 New JerseyAve. SE Washington, DC 20590 Re: Exemption Request Section 333 ofthe FAA Reform Act Dear Sir/Madam: This petition is being submitted pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (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 belowto allow operation ofour sUAS commercially in airspace regulated bythe Federal Aviation Administration (FAA) so long as such operations are conducted with and underthe 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 interestin 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 notviable options for the average consumer as they are costly and involve greater risks to everyone involved; i.e. the use oflarger 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 ofthe UAV/UAS, we will conduct a Pre-Flight Safety Inspection as required. See ExhibitA 

# 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 notbefore a thorough inspection ofthe property. Strategic Property Solutions, LLC sUAS operators will be required to: • Be at least 21 years old and have a currentUnited States passport and drivers licenses and a minimum ofa Pilot Private License see Exhibit 

# B. • Pass the written FAA approved aeronautical knowledge test • Obtain a Letter ofQualification by the Company • Conduct a preflightinspection, which includes specific aircraft, and control station systems check. • Have a minimum of 25 hours ofin field training • Have current medical and be ofsound 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 ofthe operator or visual observer • Unmanned aircraft will not operate over any person not directly involved in the operations • Daylight-only operations • Mustyield right-of-way to all other aircraft • Maximum airspeed of25 mph • Maximum altitude of400 feet above ground level • Minimum weathervisibility of 3 miles from control station • Operations are limited to Class Gairspace Strategic Property Solutions, LLC is seeking relieffrom FAA airworthiness certification aircraft, however all aircraft will be registered with the FAA and N number displayed in the largestpracticable 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 thatifa 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 ofaircraft. 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 setflight boundaries. See Exhibits Dand E. Strategic Property Solutions, LLC respectfully request exemption under Section 333 to enable us to operate safe, lowrisk commercial sUAS operations for the activities stated. Strategic Property Solutions, LLC will at all times respectthe space and privacy ofcitizens 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 

# •

• • 

# • • 

# • • • • 

# • • • • • • 

# • • • 

# • • • • • 

# • • • • • • Checkin2 all control surfaces for silllls ofdama2e, loose hin2es, and overall condition; Lookin2 overthewin2/rotors to
ensure they are in 20od structural condition and properly secured; Checkmotor/enlline and mountin2 attached to the airframe; Stndy propellers I mountin2 hardware (ti2ht) I rotor blades for chips and deformation; Checkthe landin2 2ear for dama2e and function Test electrical connections, plu22ed in and secure Ensure photo I video equipmentmountin2 system is secure and operationaL Check location ofGPS equipment controllin2 the autopilot
. Check the IMU movements inthe 2round control software
. UAV in stabilization mode, ensure control surfaces move towards the correct positions UAVI Drone is in a level location safe for takeoff FPV I Power up 2round station FPV I Power up Video receiver I 2022Ies Ifusin2 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 transmitteron Connect I power on battery to airframe Ensure led indicators and audibletones are correct FPV, confirm video is in monitorI2022Ies 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 BUNITED 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



## - o 7/17/ 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 Publ ication 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 

## Exhi bit 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
.Exhibit
E Aircraft !Camera

DJI Phantom

3 Specs Professional

& Advanced !weight (Including Battery And Propellers): 1280 g Diagonal Size (Including Propellers): 590mm Max Ascent Speed: Sm/s Max Descent Speed: **~mls** Hover Accuracy: !Vertical:

+ 1 - 10cm **~orizontal:** +1- 1m Max Speed: 16 m/s (AITI mode, no wind) Max Altitude Above Sea Level: 6000m Operating Temperature: 1ooc to 40°C GPS Mode: IGPS/GLONASS Sensor: Sony EXMOR 1/2.3" Effective pixels: 12.4 M (total pixels: 12.76 M) Lens: !Fov 94° 20 mm (35 rom format equivalent) f/2.8, focus at oo ISO Range: 100-3200 (video) 100-1600 (photo) ISh utter Speed: !8s -118000s Image Max Size: f4ooo x3000 !Still Photography Modes: Single Shot tBurst Shooting:

3 1 517 shots !Auto Exposure Bracketing (AEB):

3 / 5!Gimbal Vision !Positioning !Remote icon troller **racketed** Frames at 0.7EV Bias ime

- lapse Video Recording Modes Phantom

3 Professional: 4096x2160p
24 / 25, 3840x2160p
24 / 25 / 30 : 1920x1080p
24 / 25 / 30 / 48 / 50 / 60 1280x720p
24 / 25 / 30 / 48 / 50 / 60 Phantom

3 Advanced: !Fnn: 1920xl080p 24/25/30/48

/ 50/60 ltm: 1280x720p
24 / 25 / 30 / 48 / 50 / 60 !Supported SO Card Types: !Micro SD !Max capacity: 64GB. Class 10 or UHS-1 rating required Max Bitrate Of Video Storage: **~OMbps** ' Supported File Formats: **AT32/exFAT** hoto: JPEG, DNG ideo: MP4, MOV (MPEG-4
A VC
/ H.264) Operating Temperature: I0 ° C to40°C Controllable Range: !Pitch -90° to +30° Stabilization: **~-axis** (pitch, roll, yaw) Max Velocity: **ess** than 8 m/s (when 2m above ground) ltitude Range: Ocm-300cm Operating Range: **~Ocm-300cm** Operating Environment: Surface with clear pattern and adequate lighting (Lux > 15) Operating Frequency: f2.400 GHz-2.483 GHz Max Distance: 2000m (outdoors and unobstructed) !video Output Port: USBOperatingTemperature:0°C-40°CBattery:6000mAhLiPo2SMobileDeviceHolder:tFortabletorphoneIReceiverSensitivity(1%PER):-101dBm±2dBm!TransmitterPower(EIRP):!Fcc:20dBm!•1cE.16dBmVoltage:1.2A@7.4V!BatteryCharger!voltage:17.4VRatedPowerPhantom3Professional:IOOWPhantom3Advanced:57WIntelligentFlightsapacity:Battery0mAholtage:15.2VBatteryType:ILiPo4SEnergy:i68WhINetWeight:p65gMaxFlightTime:Approximately23minutesOperatingTemperature:-10°Cto40°CMaxChargingPower:lOOWAppILiveView!MobileApp:pnPilotEIRP:lOOmW Live View Working Frequency: 2.4GHziSM Live View Quality: I720P@ 30fps (depending on conditions and mobile device) Latency: 220ms (depending on conditions and mobile device) Required Operating Systems: liOS 8.0 or later ! Android 4.1.2 or later Recommended Devices: ·as: iPhone 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 i + Cellular, iPad mini 3, and iPad mini 3 Wi
- Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, and iPhone

6 Plus ndroid: Samsung S5, Note 3, Sony Xperia Z3, Google Nexus
7 II, Google Nexus 9, Mi 3, Nubia Z7 mini *S u ooort for additional Android devices available
as **testin~:r** and development continues