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 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 91.121

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 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 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". An 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 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 91.409 (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.

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 D1I
Phantom 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 used 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

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) 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 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. I do not pilot my

UAS outside of GPS lock under any circumstances.

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 necessary 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 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

pose much less of a safety concern for 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 more 

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 3rd grade 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 years. 

Thank you for your consideration.

Harlin Parker