Harlin Parker

525 Naughright Road Long Valley, NJ 07853 C. 646.765.3355 harlinp@yahoo.com
To: Federal Aviation Administration

Regulations from which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 4 5.23 (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 91.121 14 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 exc eption. 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 i mportance 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 ma rked 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 ma intenance 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 will 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". A n equivalent level of safety will be provided by preflight protoco) 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 tha t 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 a n equivalent level of safety as achieved by current regulations because my UAS does not carry pilot nor passenger. W hile 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 91.409 (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 in itiating each flight.
Harlin Parker 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 D1IPhantom 2 Plus. 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 use d at speeds much less than its top speed of 33.5 mph. Due to the UAS being battery powered there are no combustible fuels onboard. Maximum flight time for this particular UAS is 25 minutes battery life, flights to be terminated with 25% battery life remain ing. 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) I do not operate within 10 miles of an airport. 2) I land my UAS prior to manufacturer recommended minimum level of battery power. 3) I pilot my UAS through remote con trol 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. I do not pilot my UAS outside of GPS lock under any circumstan ces. 5) I actively analyze flight data and other sources of information to constantly update and enhance safety protocols 6) I conduct extensive pre

-flight inspections and protocol, during which safety carries primary importance 7) I always obtain all nece ssary permissions prior to operation; and, 8) I have procedures in place to abort flights in the event of safety breaches or potential danger. The use of an UAS in the real estate industry provides both buyers and sellers a higher level of service. For a b uyer 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 proper ty, 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 achi eve the same result. Wecan 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 pose much less of a safety concern fo r the general public when compared to larger manned aircraft. 9) The PIC will only be Harlin Parker, myself. I have a VFR Private Pilot Certificate (certificate no. 3724559 issued Sept. 9, 2013) and have more than 210 hours of flight time, including m ore than 150 hours as PIC. I have a clean safety rating, have been a member of the FAA FAAST program and continually take online safety courses and attend AOPA and FAA FAAST approved safety seminars. 10) I am in excellent health, passing my FAA 3 rd grad e health exams. I have no physical or mental health issues that affect my private pilot certificate. In addition, I am known to be of good character and lawful in my conduct, being a private investigator licensed and bonded in the states of New York and New Jersey for many yea rs. Thank you for your consideration. Harlin Parker