May, 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 or Madam: Pursuant to the Section 333 of the FAA Modernization and 

Dear Sir or Madam: 

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

Michael P. Rennels (the "applicant"), operator of an Unmanned Aircraft Systems ("UAS") seeks an 

exemption from the Federal Aviation Regulations ("FARs") to allow for commercial operation of aerial 

filming and photographing to include: infrastructure inspections, aerial acquisition (mapping), real 

estate, and other applicable areas for pre-planned, controlled areas in Oklahoma. 

Commercial operations will be performed only at the request of, and with the authorization and 

permission of clients or their authorized agents in order to facilitate commerce and raise awareness of 

the beneficial uses of small unmanned aircraft systems. 

Applicant Michael P. Rennels 2019 N. Shartel Ave Oklahoma City, Oklahoma 73103 

Attachments DJl 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 91.12114 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. A equivalent 

level of safety will be maintained by keeping the flight manual at ground control point where the pilot 

wil) 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 "DJI 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 these 

section only apply to aircraft with an airworthiness certificate, theses 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. 

Michael P. Rennels 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 speed less than 33.5 mph, and 

with a maximum flight time of 25 minutes,. The drone to be used is a 011 Phantom 2 Plus V3. At 2.74 

pounds the weight of the UAS 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 on board. Maximum flight time for this particular UAS is 25 minutes battery life, flights 

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

area associated with the aircraft to be utilized 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 "DJI Pilot Training" for safety precautions I use for every flight. 

Additionally: 1)1 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)1 actively analyze flight data and other sources of 

information to constantly update and enhance safety protocol's 6)1 conduct extensive pre-flight 

inspections and protocol, during which safety carries primary importance 7)1 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. 9) 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 poses much less of a safety concern 

for the general public when compared to larger manned aircraft. 

Thank you for your consideration. 

'7Yj ~ f1 R~ .)·;;.,_~orr- Michael P. Rennels 
PHANT M PIL TRAIN I UID 

Earning Your Stripes 

Learn IVlore: www.dji.com 
product is not suitable for people under the age of 18. Please carefully read the "Quick 

Start Guide", "User Guide", disclaimer, fu!!y watch the "Quick Start Videos" before 

using the PHANTOIVL Users should make every effort to fly regularly in to improve 

their flight skills as an advanced level pilot (***) . Please fly safely and responsibly. 

Please follow these guidelines prior to flying your Phantom: 

GAiways turn on the Remote Controller prior to turning 011 the Phantom. 

@Toggle Sl, S2 to the top. 

8 Be sure there are no distractions when you're flying. 

Whf'"n starting your training, be sure you are in a very large open area. Be aware of your 

surroundings. Always fly in areas void of obstacles and away from traffic and people. 

~ Before actually takir•g off, be sure you have calibrated the compass and you have full 

GPS satellite reception (Slow Continuous Green Flashing). 

8 Never fly over 400 feet. 

f) During training, stay behind your imaginary barrier and never fly behind yourself. 

@) When in doubt, gently pull down on the throttle stick and land. 

f) DO NOT P/\N 

The aircraft camera should face AWAY from the pilot before takeoff. 

CAUTION 

DO NOT fly the Phantom within a radius of 2 meters. 

FORBIDDEN 

DO NOT touch the propellers after the Phantom has been started. 

NO TOUCH 
Take off and land with battery facing you. 

Hover in one spot keeping battery facing you, make 

sure to control Left/Right/Forward/Hack movement 

Rotate left, rotate right but try to keep the battery 

pointed at yourself. 

0 

II 
Slowly fly fNward/back/left/rlght with back of 

Phantom pointed at yourself, 

Fly forward to a spot 20--30 feet away. 

Then fly back keeping the battery pointed at yourself. 

------------------

Hark r:; spot (El) on t.he gmund lOft away from the Phantom 's 

take off point. !---lover and fly towards that spot and land at 

the spot (8). Then go back into a hover and br-ing the Phantom 

back to its ori;:,1inal position (A) and land again. 

B* 

~ II 
Fly left 10ft away from your take-off point, then fly right 

10ft frorn your take-off point all keeping battery 

pointed at yourself 

3 meters L-~~__j 

Then, \Vhile keeping the camera pointed forward, 

fly a 4 !Joint square box formation going clockwise. 

Be sure to be in control and stop and hover in place 

at each point before proceeding to the next point. 

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-- - - - ~-- -- - -""{ # 

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- - - - - - - - - - -.... .•. - - - - - - -- --· 

Do the sDme as above but fly the 4 point box formation 

counter-clockwise. Be sure to be in control and stop 

and hover in place at each point before proceeding 

to the next point. 

------"'iff!~-----"'! " I \ 

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/ ___________ ,___ __________ . \ 
!n a hover, starting with the battery pointed at yourself, 

rotate 360 degrees clockwise . 

................................................... ........................................... ......................................................................... ................................................................................................. .. ................... .......................... ................ ............. .......................... 31~·-·· .............................. ! .................................... . 

In a hover, starting with the battery pointed at yourself, 

rotate 360 degrees counter ... clockwise. 

Startinf.J with the battery pointed at yourself, go into a hover. 

Then rotate the Phantom 90 degrees facing left, and fly a 4 

point .square box formation going clockwise. Be .sure to be in 

control and stop and hover in place at each point before 

proceeding to the next point. 

f 

{ 

?---- -.... ---- ... r " ~ 

' 

® 
# 

..a4 

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# 

Starting with the battery pointed at yourself, go into a hover. 

Then rotate the Phantom 90 degrees facinq ri~Jht, and fly a 4 

point square box forrnation goinq counter·-clockwise. 

Be sure to be in control and stop and hover in place at •~ach 

point before ~xoceedin~j to the next point. 

J 

I 

.,. \ 

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-------~----------· 

Wit!• the battery pointed at yourself, fly a circle. Try to 

keep the altitude and also the circle as uniform as possible. 

-------------- -- "' ... 

... " ~-- ________ ___, ______ _ 

I· .. Jover with the camera pointc;d at yourself and try to kc~i'"P 

the Phantom in one place. 
Fly a circle and keep the carnera pointed towards you. 

Be sure to keep the altitude the same and the circle as 

uniform as possible. 

~-- ---·-···------ ---- .... '*" .... ~ -~ 

Fly a 4 point square box clockwise while keeping the carnera 

facin~j in your direction. 

.,· 

- - - - - ~·- - - - -'% 

I " ' 

.. -----------

Fly a Lj. point square box counter-clockwise while keeping 

the camera facing in your direction . 

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.:.. - - ~~ - -4- - -'- -~ " " 

\ 

--------11------------· 
Fly a 4 point square box clockwise and rotate the 

phantorn in the direction of travel. 

I 

f " 

; 

.f 

- - - - - ~- - - - -"t 

' ' 

I. ----------• 

Fly a circle counter-clockwise and keep the camer<:i pointed 

in the directior! of travel. Be sure to keep the altitude the 

same and the circle as uniform as possible. 

-~ ---------~------- ~~~ 

Fly a circle counter-clockwise with the camera pointed at the 

center of the circle. Be sure to keep the altitude the same 

and the circle as uniform as possible. 

----------·------ ~- . ··---·-"'·-···e::•,----,....... = -

--- li!lllllll!i-------------
Fly a figure 8 without rotating the Phcmtom. Be sure to keep 

the altitude the same and the circle as uniform as possible. 

-----~---,.,.,=- .... 

---

Fly a FifjUre 8 with the camera of the Phantom pointed in the 

direction of travel. Be sure to keep the altitude the same and 

the circle as uniform as possible. 

-----......... 

r··:ly F'igure Ei patterns while experirnentin~J with differer;t orientations. 

Fof' example, camera always pointed in a given direction or opposite/ 

left/right the direction of travel, etc. Be sure to keep the altitude the 

same and the ci;·cle as uniform as possible. 

--- ------

" 

~-------~-----------~-
Retum Home & land Mode 

Be sure you are in a large open area, Before you off, 

make sure you have a good GPS lock by ensuring your LED 

indicators are flashing Greer!. Fly the Phantom at least 50ft 

away from your take off point Turn off the Remote Controller. 

·rhe Phantom will enter it's failsafe Return~To-Home tviode. 

Let the Phanton: finish it's routine and land itself within 2 meters 

of the take off point. 

------·----------! 

' 

15 meters 

lnten:::epting Retum Home & bmd Mode 

Be sure you are in a large open area. Before you take off, make 

r-\" ! ~)l@ '-. .......... -./ 

sure you have a GPS lock by ensuring your LED indicators 

are flashing Green. Fly the Phantom 50ft away frorn your take 

off point Turn off the Remote Controller. The Phantom will 

enter it's failsafe Return-To-Home tviode. \IVhen the Phantom 

is retun1ing home, you can intercept RH··l tviode by switching 

the S1 Switch from the top position to the middle 01" lower 

position, then continue the Phantom. 

' 

1 

·15 meters 
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