May, 2015 U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., Washington, DC 20590 RE: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations Dear Sir or Madam: Pursuanttothe Section 333 ofthe FAA Modernization and Dear Sir or Madam: Pursuanttothe Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act"), Michael P. Rennels (the "applicant"), operator ofan Unmanned Aircraft Systems ("UAS") seeks an exemption from the Federal Aviation Regulations ("FARs") to allowfor commercial operation ofaerial filming and photographingto include: infrastructure inspections, aerial acquisition (mapping), real estate, and other applicable areas for pre-planned, controlled areas in Oklahoma. Commercial operationswill be performed only atthe request of, and withthe authorization and permission ofclients ortheir authorized agents in ordertofacilitate commerce and raise awareness of the beneficial uses ofsmall unmanned aircraft systems.
Applicant Michael P. Rennels 2019 N. Shartel Ave Oklahoma City, Oklahoma 73103 Attachments DJl PilotTraining Regulations from which the exemption is requested: 14CFR Part 21 subpart H 14 CFR 45.23 (b) 14CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14CFR 91.109 14CFR 91.119 (c) 14 CFR 91.12114CFR 91.203 (a) and (b) 14 CFR 91.405 (a) 14CFR 91.407 (a) (1) 14 CFR 91.409 {a) (2) 14 CFR 91.417 (a) and (b) Extent of relief Iseek, and why 14CFR 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, orsafer, than a conventional aircraft operatingwith an airworthiness certificate without said restrictions. 14CFR 45.23 (b) Due tothe size ofthis UAS itdoes not have acockpit, cabin, or pilotstation on whichto 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. Understandingthe 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 UAS fuselage. The equivalent level of safety will be provided by havingthe UAS marked on itsfuselage as required. 14CFR 91.7 (a) As there will be no airworthiness certificate forthe aircraft, should this exemption be granted, no FAA regulatory standard will existfordetermining airworthiness. Given the size oftheaircraft for maintenance and use ofsafety check list priorto each flight an equivalent level ofsafety will be provided. 14 CFR 91.9 (b) (2) Given the size and configuration, the UAS has no abilityto carry aflight manual on the aircraft. There is no room, capacity, or pilot on board to adequately carry flight manual. A equivalent level ofsafetywill be maintained by keeping theflight manual atground control pointwhere the pilot wil) 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 "DJI 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 box that communicates with the aircraftvia radio communications. The equivalent level ofsafety provided because neithera pilot nor passengerwill be carried in the aircraft, and bythe speed and size ofthe aircraft. 14 CFR 91.113 (a) and (b) Ican achieve an equivalent level ofsafety as achieved by current regulations because my UAS does notcarry pilot nor passenger. While helpful, a pilots' license will notensure 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 abilityto 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, tothe extentthey are applicable tothe UAS, atthe ground control pointwhere pilot has immediate access tothem. 14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14CFR 91.409 (a) (2), 14 CFR 91.417 (a) and (b) Given these section only applyto aircraft with an airworthiness certificate, theses sections do not apply to this applicant. As a safety precaution, operatorwill perform preflight inspections and ensure UAS is in working condition before initiating each flight. Michael P. Rennels is seeking relieffrom 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 flighttime of25 minutes,. The drone to be used is a 011 Phantom 2 Plus V3. At 2.74 pounds the weight ofthe UAS 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 atspeeds much less than it'stop speed of33.5 mph. Due to the UAS being battery powered there are no combustible fuels onboard. Maximum flighttimeforthis 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 aircraftto be utilized ifind this exception to be reasonable with an equivalent, orgreater, level ofsafetyto be reached by the operator.Safety *Please see attachment "DJI PilotTraining" for safety precautions I use for every flight. Additionally: 1)1 do notoperate within 5 miles ofan airport unless priorcontacttoAirTraffic Control or the airport manager has been made. 2) I land my UAS priorto manufacturer recommended minimum level of battery power3) I pilot my UAS through remote control by line ofsight 4} My UAS uses GPS and aflight 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 othersources 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 priorto operation; and, 8) I have procedures in place to abortflights in the event ofsafety breaches or potential danger. 9) Public InterestThe use ofan UAS in the real estate industry provides both buyers and sellers a higher level ofservice. For a buyer a higher level ofmarketing and advertising is achieved, appealingto more buyers, resulting in a quickersale oftheir home. 'Quicker home sales also helps accelerate the economy as awhole. Buyers experience the benefit ofencompassing awhole property, sometimes several acres, in one photo or ashortvideo. Not only does this benefitthe specific home seller or home buyer, but it benefitsthe 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 poses much less ofa safety concern forthe general public when compared to larger manned aircraft. Thank you for your consideration.



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Michael P. Rennels

# PHANT M PIL TRAINI 

# UID Earning Your Stripes

Learn IVlore: www.dji.comproduct 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 ofyour 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 TOUCHTake off and land with battery facing you.

Hover in one spot keeping batteryfacing 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 atyourself.



## ------------------ Hark r:; spot (El) ont.he gmund lOft awayfrom the Phantom 's take off point. !---lover and fly towards that spot and land at the spot (8). Then go back into a hoverand br-ing the Phantom back to its ori;:,1inal position (A) and land again. 

## B*

# ~ IIFly 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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### !n a hover, starting with the battery pointed at yourself, rotate 

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..................................... 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.

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## ..a4' ' # 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.

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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.



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..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.

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### Fly a 

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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.

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Fly a circle counter-clockwise with the camera pointed at the center ofthe circle. Be sure to keep the altitude the same and the circle as uniform as possible.



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### Fly a figure 

### 8 without rotating the Phcmtom. Be sure to keep the altitude the same and the circle as uniform as possible.**-----~---,.,.,=-** 

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Fly a FifjUre 8 with the camera of the Phantom pointed in the direction oftravel. Be sure to keep the altitude the same and the circle as uniform as possible.



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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.



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### 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 offthe Remote Controller. ·rhe Phantom will enter it's failsafe**Return~To-Home** tviode. Letthe Phanton: finish it's routine and land itselfwithin 2 meters of the take off point.



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15 meters



### lnten:::epting Retum Home & 

### bmd Mode Be sure you are in a large open area. Before you take off, make r-\" !**~)l@** '-.

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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.

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### ·15 meters

## www.dji.com