January 22, 2015 

Federal Aviation Administration: 

On behalf of Straw Investment Group, LLC (DBA “Randolph 

Housing Solutions”) I would like to formally submit for an 

exemption from part 21, subpart H; and Sections 45.23(b), 

91.7(a), 91.9(b)(2), 91.119, 91.121, 91.151(a), 91.203(a) and 

(b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and 

(b) of Title 14, Code of Federal Regulations (14 CFR). This 

proposed exemption would allow our operation of unmanned 

aircraft systems (UAS) for the purpose of aerial videography 

and to augment real estate listing videos in various 

metropolitan areas. 

As found in Exemption No. 11138 (Trudeau), the FAA 

recently approved similar use of a PHANTOM 2 UAS. 

We will operate a UAS, the DJI PHANTOM 2, which is 

comprised of an unmanned aircraft (UA or PHANTOM), an 

attached GoPro Hero 3+ camera and a transportable ground 

station. 

The PHANTOM 2 is a quad-copter with a maximum gross 

weight of about 3 pounds. It is equipped with four rotors that 

are driven by electric motors powered by batteries. The UA 

has a maximum airspeed of 30 knots. We will operate the 

UA over various metropolitan areas, primarily around 

Indianapolis, IN, to enhance academic community/ business 

awareness and augment real estate listing videos. 

UAS Operating Parameters 

We will abide by the following additional operating conditions 

under this exemption, which ensures a level of safety at least 

equal to existing rules: 

• Operate UAS below 300 feet and within a radius distance 
of 1000 feet from the controller to aid in direct line of sight 

visual observation; 

• Obtain permission from the owner/controller of any vessels, 

vehicles and structures when operations may be conducted 

closer than 500 feet to any such vessels, vehicles or 

structures; we will conduct a safety assessment of the risk of 

operating closer to those objects and determine that it does 

not present an undue hazard; 

• Operate the UAS for 5-10 minutes per flight;• land UAS 

prior to the manufacturer’s recommended minimum level of 

battery power; 

• Operate UAS during daylight hours only within visual line of 

sight (VLOS); 

• Use the UAS’ global positioning system (GPS) flight safety 

feature whereby it hovers and then slowly lands if 

communication with the remote control pilot is lost; 

• Conduct all operations under the flight safety protocols 

(including posting a warning sign reading: “Attention Aerial 

Photography in Progress – Remain Back 150 feet”) 

contained in the operating documents and will actively 

analyze flight data and other sources of information to 

constantly update and enhance safety protocols; 

• Contact respective airports if operations will be within 5 

miles to advise them of his estimated flight time, flight 

duration, elevation of flight and other pertinent information; 

• Always obtain all necessary permissions prior to operation; 

•Have procedures in place to abort flights in the event of 

safety breaches or potential danger; 

• Only operate in safe environments that are strictly 
controlled, are away from power lines, elevated lights, 

airports and densely populated areas (defined by areas 

depicted in “yellow” on VFR charts and through obtaining 

information regarding congested areas from the local Flight 

Standards District Office (FSDO); 

• Conduct extensive preflight inspections and protocols, 

during which safety carries primary importance (reference 

PHANTOM Flying Flow Chart and User Manual). 

UAS Pilot in Command (PIC) 

Anthony Straw, our Chief Pilot, holds a FAA Commercial 

Pilot license and Airline Transport Pilot Rating, first-class 

medical certificate, multi-engine instrument rating, is a 

current Air Force Instructor Pilot, and has substantial flight 

time in numerous types of aircraft. Given his flight 

background and experience, he has the knowledge required 

to ensure the high level of safety required by current 

regulations. Any other pilots who would conduct flights will 

hold a minimum of a FAA Private Pilot License and thirdclass medical. 

Regarding UAS operational training, we have flown 

numerous practice flights in remote areas as hobbyists 

simulating flights for future commercial use to gain 

familiarization with the characteristics of the UAS’ 

performance under different temperature and weather 

conditions. 

Any PIC operating our UAS will have accumulated and 

logged, in a manner consistent with 14 CFR 61.51(b), 25 

hours of total time as a UAS rotorcraft pilot including at least 

10 hours logged as a UAS pilot with a multi-rotor UAS. The 

PIC will also have accumulated and logged a minimum of 5 

hours as a UAS pilot operating the same make and model of 
UAS to be used for operations. In addition to the hour 

requirements, the PIC will accomplish 3 takeoffs and 

landings in the preceding 90 days (for currency purposes) 

prior to any flight. 

Specific Exemptions Requested 

Given the size, weight, speed, and limited operating area 

associated with the UA, we feel an exemption from 14 CFR 

part 21, Subpart H (Airworthiness Certificates) and § 

91.203(a) and (b) (Certifications required), subject to certain 

conditions and limitations, is warranted and meets the 

requirements for an equivalent level of safety under 14 CFR 

part 11 and Section 333 of P.L. 112-95 (Section 333). 

We request an exemption from § 45.23 Marking of the 

aircraft because the UA will not have a cabin, cockpit or pilot 

station on which to mark certain words or phrases. Further, 

the two-inch lettering is difficult to place on such a small 

aircraft with dimensions smaller than the minimal lettering 

requirement. Regardless of this, we can mark the UAS in the 

largest possible lettering by placing the word “Experimental” 

on its fuselage as required by § 45.29(f) so that anyone will 

see the markings. 

We request an exemption from § 91.7(a) which prohibits the 

operation of an aircraft without an airworthiness certificate, 

since there is currently no certificate applicable to our 

operation, this regulation is inapplicable. 

We request an exemption from §§ 91.405(a), 91.407(a)(1), 

91.409(a)(2) and 91.417(a) and (b) Maintenance inspections 

since they only apply to aircraft with an airworthiness 

certificate. However, as a safety precaution we will perform a 

preflight inspection of the UAS before each flight as outlined 

in the attached operating documents. 
We request an exemption from § 91.9(b)(2) which requires 

an aircraft flight manual in the aircraft, however since there 

are no pilots or passengers on board the aircraft and given 

its size, this regulation is inapplicable. We believe an 

equivalent level of safety will be achieved by maintaining a 

safety/flight manual with the UAS ground station. 

We request an exemption from § 91.119 which prescribes 

safe altitudes for the operation of civil aircraft, but it allows 

helicopters to be operated at lower altitudes in certain 

conditions. We will not operate our UAS above the altitude of 

300 feet above ground level (AGL) and will also only operate 

in safe areas away from the public and traffic, thus “providing 

a level of safety at least equivalent to or below those in 

relation to mini- mum safe altitudes.” Given the size, weight, 

maneuverability, and speed of the UAS, an equivalent or 

higher level of safety will be achieved. 

We request an exemption from § 91.121 Altimeter settings 

as it is inapplicable since the UAS utilizes electronic GPS 

with a barometric sensor. 

We request an exemption from § 91.151(a) Fuel 

requirements for flight in VFR conditions. The UAV is 100% 

electric and two low battery alerts are issued - per the 

operating documents, the UAV will be landed at the first 

alert. Also, our flights will last only 5-10 minutes each, and 

the UAS has an automated function which results in 

immediate landing when a low battery is detected. The PIC 

will not begin a flight unless (considering wind and forecast 

weather conditions) there is enough power to fly to the first 

point of intended landing and, assuming normal cruising 

speed, land the UA with 30% battery power remaining. 
Public Interest 

Aerial videography for geographical awareness and for real 

estate marketing has been around for a long time through 

manned fixed wing aircraft and helicopters, but for small 

business owners, its expense has been cost-prohibitive. By 

granting this exemption we would be able to provide this 

service at a much lower cost. Further, our small UAS will 

pose no threat to the public given its small size and lack of 

combustible fuel when com- pared to larger manned aircraft. 

Additionally, the operation of our UAS will minimize ecological damage and promote economic growth by providing

information to companies looking to relocate or build in the 

metro areas we service. 

Summary 

We will comply with all of the following conditions and 

limitations should this grant of exemption be provided: 

1) Operations will be limited to the following aircraft 

described in the operating documents which is a quad-rotor 

aircraft weighing less than 3 pounds: PHANTOM 2 Unmanned Aircraft System. 

2) The UA will not be flown at an indicated airspeed 

exceeding 30 knots. 

3) The UA will be operated at an altitude of no more than 

300 feet above ground level (AGL), as indicated by the 

procedures specified in the operating documents. All 

altitudes reported to ATC must be in feet AGL. 

4) The UA will be operated within visual line of sight (VLOS) 

of the Pilot In Command (PIC) at all times. 

5) All operations will utilize a visual observer (VO). The UA 

will be operated within the visual line of sight (VLOS) of the 
VO at all times. The VO and PIC will be able to communicate 

verbally at all times. The PIC will be designated before the 

flight and will not transfer his or her designation for the 

duration of the flight. The PIC will ensure that the VO can 

perform the functions prescribed in the operating documents. 

6) The operating documents will be accessible during UAS 

operations and made available to the Administrator upon 

request. Any revisions to the operating documents will be 

presented to the Administrator upon request. 

7) Prior to each flight, the PIC will inspect the UAS to ensure 

it is in a condition for safe flight. If the inspection reveals a 

condition that affects the safe operation of the UAS, the UAS 

will not be operated until the necessary maintenance has 

been performed and the UAS is found to be in a condition for 

safe flight. The Ground Control Station will be included in the 

preflight inspection. All maintenance and alterations will be 

properly documented in the aircraft records. 

8) Any UAS maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight 

critical component, will undergo a functional test flight. The 

PIC who conducts the functional test flight will make an entry 

in the aircraft records. 

9) The pre-flight inspection section in the operating 

documents will account for all discrepancies, i.e. inoperable 

components, items, or equipment, not already covered in the 

relevant sections of the operating documents. 

10) We will follow the UAS manufacturer’s 

aircraft/component, maintenance, overhaul, replacement, 

inspection, and life limit requirements. 

11) We will carry out maintenance, inspections, and record 

keeping requirements, in accordance with the operating 
documents. Maintenance, inspection, and alterations will be 

noted in the aircraft records, including total flight hours, 

description of work accomplished, and the signature of the 

authorized person returning the UAS to service. 

12) Each UAS operated will comply with all manufacturer 

Safety Bulletins. 

13) An authorized person will make an entry in the aircraft 

record of the corrective action taken against discrepancies 

discovered between inspections. 

14) UAS operations will be conducted by a PIC possessing 

at least a private pilot certificate and at least a current thirdclass medical certificate. The PIC will also meet the flight 

review requirements specified in 14 CFR 61.56 in an aircraft 

in which the PIC is rated on his or her pilot certificate. 

15) Prior to operations conducted for the purpose of aerial 

videography/cinematography and augmenting real estate 

listing videos (or similar operations), the PIC will have accumulated and logged, in a manner consistent with 14 CFR 

61.51(b), a minimum of 25 hours of total time as a UAS 

rotorcraft pilot including at least 10 hours logged as a UAS 

pilot with a multi-rotor UAS. 

16) Prior to operations conducted for the purpose of aerial 

videography/cinematography and augmenting real estate 

listing videos (or similar operations), the PIC will have accumulated and logged, in a manner consistent with 14 CFR 

61.51(b), a minimum of 5 hours as UAS pilot operating the 

make and model of the UAS to be used in operations. The 

PIC will accomplish 3 takeoffs and landings in the preceding 

90 days (for currency purposes). 

17) The PIC will not operate the UAS for the purpose of

aerial videography/cinematography and augmenting real 
estate listing videos (or similar operations), unless the PIC 

has demonstrated and logged in a manner consistent with 

14 CFR 61.51(b), the ability to safely operate the UAS in a 

manner consistent with the operating documents, including 

evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and 

structures. 

18) UAS operations will not be conducted during night, as 

defined in 14 CFR 1.1. All operations will be conducted 

under visual meteorological conditions (VMC). 

19) The UA will not operate within 5 nautical miles of an 

airport reference point as denoted on a current FAApublished aeronautical chart. 

20) The UA will not be operated less than 500 feet below or 

less than 2,000 feet horizontally from a cloud or when 

visibility is less than 3 statute miles from the PIC. 

21) If a UA loses communications or loses its GPS signal, it 

will return to a predetermined location within the planned 

operating area and land or be recovered in accordance with 

the operating documents. 

22) The PIC will abort a flight in the event of unpredicted 

obstacles or emergencies in accordance with the operating 

documents. 

23) The PIC will not begin a flight unless (considering wind 

and forecast weather conditions) there is enough power to 

fly at normal cruising speed to the intended landing point and 

land the UA with 30% battery power remaining. 

24) We will obtain an Air Traffic Organization (ATO) issued 

Certificate of Waiver or Authorization (COA) prior to 

conducting any operations, and also request a Notice to 
Airman (NOTAM) not more than 72 hours in advance, but 

not less than 48 hours prior to the operation. 

25) Before conducting operations, the radio frequency 

spectrum used for operation and control of the UA will 

comply with the Federal Communications Commission 

(FCC) or other appropriate government oversight agency 

requirements. 

26) The documents required under 14 CFR 91.9 and 91.203 

will be available to the PIC at the Ground Control Station of 

the UAS any time the UAS is operating. These documents 

will be made available to the Administrator or any law 

enforcement official upon request. 

27) The UA will remain clear and yield the right of way to all 

manned aviation operations and activities at all times. 

28) The UAS will not be operated by the PIC from any 

moving device or vehicle. 

29) The UA will not be operated over congested or densely 

populated areas. 

30) Flight operations will be conducted at least 500 feet from 

all nonparticipating per- sons, vessels, vehicles, and 

structures unless: 

a. Barriers or structures are present that sufficiently protect 

nonparticipating persons from the UA and/or debris in the 

event of an accident. We will ensure that nonparticipating 

persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and 

are within 500 feet of the UA, flight operations must cease 

immediately and/or; 

b. The aircraft is operated near vessels, vehicles or 

structures where the owner/controller of such vessels, 
vehicles or structures has granted permission and the PIC 

has made a safety assessment of the risk of operating closer 

to those objects and deter- mined that it does not present an 

undue hazard, and; 

c. Operations nearer to the PIC, VO, operator trainees or 

essential persons do not present an undue hazard to those 

persons per § 91.119(a). 

31) All operations will be conducted over private or 

controlled-access property with permission from the land 

owner/controller or authorized representative. Permission 

from land owner/controller or authorized representative will 

be obtained for each flight to be conducted. 

32) Any incident, accident, or flight operation that 

transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA will be 

reported to the FAA's UAS Integration Office (AFS-80) within 

24 hours. Accidents will be reported to the National 

Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov. 

Respectfully,

Anthony M. Straw

Managing Partner, Straw Investment Group, LLC

830-313-8306