To: U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Rm. W12-140

1200 New Jersey Ave, SE

Washington, DC 20590

Fr: Charles Rankin

1675 NC Hwy 42 

Goldston, NC. 27252

Date: March 31, 2015

Regarding: FAA Exemption Rulemaking Section 333 of the FAA Reform Act

and Part 11- 14 C.F.R. § 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a) &

(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a) &

(b) 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a) & (b)

Dear Sir or Madam:

I, Charles Rankin, am requesting exemption from the Federal Aviation Regulations 

(“FARs”) listed below and pursuant to the FAA Modernization and Reform Act of 2012 

and the procedures contained within 14 C.F.R. 11. so I may commercially operate a 

small ultra light unmanned aircraft system (“UAS”), specifically the Phantom 3 

Professional, quad-copter Unmanned Aircraft (UAS) or equivalent and ground stationbased equipment and crew for the purpose of photography/videography of commercial 

and residential properties.

I have been a UAS hobbyist for over 3 years, both without incident. In 2008 I 

established a Real Estate Agency called Rankin Commercial Properties LLC, and wish 

to add Residential and Commercial photography/videography services to my portfolio.

Specifically, I wish to provide aerial imaging to Homeowners, and Commercial entities in 

need of aerial photography/Videography. With the advancement of Internet technology 

and consumer adoption of shopping for properties online, the demand for highresolution aerial graphics and video is unprecedented. As a hobbyist, I understand the 

seriousness, necessity and importance of pre-flight and in-flight safety measures to 

ensure public safety. As a pilot of an UAS, all UAS pertinent safety and risk 

management measures as specified in the FAA’s Risk Management Handbook

shall be complied with.

A grant of my exemption request, by the FAA, would permit operation of ultra

lightweight and unmanned UAS to operate in predetermined areas away from the 

general public, airports, heliports and vehicular traffic, primarily over individual

properties/communities for the purpose of recording real-estate listings (photo/video).
All flights shall be logged and recorded to minimally include the date and time of flight,

name of pilot (PIC) and Visual Observer (VO), address or location of flight, duration of

flight, weather conditions and “flight notes” to include maximum altitude and speed

along with signatures of the PIC and VO. A copy of the images shall also be retained for

a minimum of 12 months from the date of flight.

In summary and in accordance with this request of exemption request as authorized 

and outlined by the FAA under Section 333(c) of the Reform Act specified for use of 

UAS’ for “Real Estate” purposes, I Charles Rankin will adhere to all FAA regulations at 

all times and shall conduct all flight operations in strict compliance and safety protocols 

as mandated and required by regulations and best practices. Respectfully, I request the

grant of exemption to operate ultra light weight, remote controlled UAS’s for commercial

purposes as described in this request and as allowable by law. This grant of exemption

will allow me to offer such services to private entities, other realtors and individual

homeowners who have little to no experience piloting UAS’s but have a need to market

their property in order to compete within an ever demanding technology driven real 

estate market. I submit that this application has been prepared by myself and not an

attorney using personal knowledge of existing FARs as well as utilizing excerpts from

other similar applications. Consequently, if I have unintentionally omitted any relative

FARs, I humbly request an opportunity to submit to those accidental omissions. The

essence of this application is to declare that I, Charles Rankin, meet and exceed

the FAA’s expected competency for piloting my UAS for commercial purposes and that

my UAS meets and exceeds the safety requirements as set forth by the Secretary of

Transportation thereby prompting my request for COA under Section 333.

I. Contact Information:

Charles Rankin

1675 NC Hwy 42

Goldston, NC 27252

(919)995-7805

charlie@rrgnc.com

II. The Specific section(s) of 14 C.F.R. I seek an exemption from are:

14 CFR 21;

14 C.F.R. 45.23(b);

14 CFR 61.113 (a) & (b);

14 C.F.R. 91, et seq.;

14 CFR 407 (a) (1);

14 CFR 409 (a) (2); and,

14 CFR 417 (a) & (b).

III. The extent and reason of relief I seek:

I, Charles Rankin, am seeking relief from existing FARs that currently

prohibit my use of UASs from operating commercially for the purpose of aerial
photography/videography in accordance with the FAA Modernization and Reform

Act of 2012 112 P.L. 95 § 331-334. The Reform Act Subtitle B: Unmanned

Aircraft Systems – (Sec. 332) “Requires the Secretary to develop a plan to

accelerate safely the integration by September 30, 2015, of civil unmanned aircraft

systems (UASes, or drones) into the national airspace system.” Accordingly, I

attest that my personal qualifications as well as my ultra lightweight UAS meets the

definition of such approved drones (UAS) as defined in Section 331 and allows for

exemption status consideration. Further, I humbly request that I be allowed to

commercially operate my UAS during the time period the FAA is further

establishing rules and regulations governing the operations of such craft.

The Secretary of Transportation has been asked by Congress to, among other

things, consider whether certain unmanned aircraft systems may operate safely in

the national airspace system before completion of the rule-making required under

Section 332 of the Reform Act. In making this determination, the Secretary is

required to determine which types of UASs do not create a hazard to users of the

National Airspace System or the public or pose a threat to national security in light

of the following:

• The UAS’s size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight (VLOS) of the Pilot and VO

Accordingly, all flights will be conducted by a PIC and a VO in accordance with

FAA Policy N 8900.227 Section 14 “Operational Requirements for UASs” and with

the following restrictions:

a. All aircraft will be made with a UA Gross weight of less than 55 pounds

(my exemption request is for an aircraft less than 5 lbs.)

b. All flights will occur only during daylight hours.

c. All flights will occur at or below 200 feet AGL

d. 5 nautical miles from an airport having an operational control tower; or

e. 3 NM from an airport with a published instrument flight procedure, but

not an operational tower; or

f. 2 NM from an airport without a published instrument flight procedure or

an operation tower; or

g. 2 NM from a heliport with a published instrument flight procedure.

h. For safety, no flight with winds over 10 mph.

i. Flight only in GPS mode that allows UAS to hover in place when radio

controls are released. All operations to be conducted in GPS mode only.

IV. How my request will benefit the public as a whole:

Aerial photography is a critical component of marketing commercially available

property. With today’s high-tech Internet market and ever demanding consumer, it

is more important than ever for realtors and home sellers to have their listing appear

near or at the top of Internet searches. The Multiple List Service (MLS) typically
lists home searches in hierarchy based on number of “images” or “videos”. To grab

the attention of the buyer, it is important for them to see the entire property and the

area around it. All of these elements combine to have a tremendous impact on the

outcome of a commercial or residential real estate transaction. It is much too dangerous 

and expensive to hire a manned aircraft to take these aerial images thereby making the

UAS option more cost effective and safer. There simply is not enough UAS Pilots

to cover the demand for these images, which is leading to unlicensed UAS

operators which ultimately results in untrained and unqualified operators.

V. Reasons why the exemption would not adversely affect safety; or how the

exemption would provide a level for safety at least equal to the existing rule:

An exemption would not adversely affect safety because this application applies

only to aircraft characteristics and applications within FAA specified limitations.

These limitations provide for at least an equivalent safety standard. However, my

experience as an avid hobbyist with strong practical knowledge of safe operation and 

GPS navigation in UAS operations thereby exceeding safety and improving airspace 

operations by allowing aerial imaging clients to choose an experienced Pilot that

knows how to pilot an aircraft safely and within regulated limits. In addition, by

providing unmanned services to the market place, there will be less of a demand for

manned operations, which will provide for safer and quieter residential aerial

photography.

As previously stated, all flights will be conducted by a PIC and a VO in accordance

with FAA Policy N 8900.227 Section 14 “Operational Requirements for UASs” and

with the following restrictions:

a. All aircraft will be made with a UA Gross weight of less than 55 pounds

(my exemption request is for an aircraft less than 5 lbs.)

b. All flights will occur only during daylight hours.

c. All flights will occur at or below 200 feet AGL

d. 5 nautical miles from an airport having an operational control tower; or

e. 3 NM from an airport with a published instrument flight procedure, but

not an operational tower; or

f. 2 NM from an airport without a published instrument flight procedure or

an operation tower; or

g. 2 NM from a heliport with a published instrument flight procedure.

h. Maximum total flight time for each operational flight will be 15 minutes.

Flights will be terminated at 25% battery power reserve should that occur

prior to the 15 minute limit.

i. Extensive, pre-flight briefings are required between the PIC and the VO.

j. A flight plan is required prior to each flight.

k. All aircraft operations must be conducted within manufacturer

recommended specifications.

l. All site permissions must be obtained prior to flight.
VI. A summary the FAA may publish in the Federal Register:

a. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and

The Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth

requirements for procurement of necessary airworthiness certificates in

relation to FAR §91.203(a)(1). The size, weight and enclosed operational

area of my UAS permit exemption from Part 21 because my UAS meets

(and exceeds) an equivalent level of safety pursuant to Section 333 of the

Reform Act. The FAA is authorized to exempt aircraft from the

airworthiness certificate requirement under both the Act (49 U.S.C. §

44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation

permit the FAA to exempt UAS's from the airworthiness certificate

requirement in consideration of the weight, size, speed, maneuverability

and proximity to areas such as airports and dense populations. My current

and projected UAS's meet or exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an

airworthiness certificate. As no such certificate will be applicable in the

form contemplated by the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft.

As there are no on board pilots or passengers, and given the size of the

UAS's, this Regulation is inapplicable. An equivalent level of safety will

be achieved by maintaining such manuals on location with the Pilot. The

FAA has previously issued exemptions to this regulation in Exemption

Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A,

10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as

my UAS utilizes electronic global positioning systems with a barometric

sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft

certifications and registrations. They are inapplicable for the same reasons

described above. The equivalent level of safety will be achieved by

maintaining any such required certifications and registrations with the

Pilot.

b. 14 C.F.R. § 45.23: Marking of The Aircraft.

Applicable Codes of Federal Regulation require aircraft to be marked

according to certain specifications. My UAS are, by definition, unmanned.

They therefore do not have a cabin, cockpit or pilot station on which to

mark certain words or phrases. Further, two-inch lettering is difficult to

place on such small aircraft with dimensions smaller that minimal lettering
requirement. Regardless, I will mark its UASs in the largest possible

lettering by placing the word “EXPERIMENTAL” on its fuselage as

required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me

as a spotter with the UAV will see the markings. The FAA has previously

issued exemptions to this regulation through Exemptions Nos. 8738,

10167, 10167A and 10700.c. C. 14 C.F.R. § 61.113: Private Pilot Privileges and 

Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to

non-commercial operations. I, Charles Rankin, can achieve an

equivalent level of safety as achieved by current Regulations because my

UAS does not carry any pilots or passengers. Further, I do possess experience and 

knowledge with my equipment through hobby uses, which helps my remote control 

piloting skills and factors in my experience in assessing any flight risks. The risks 

attended to the operation of my UAS is far less than the risk levels inherent in the

commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing

me to operate my UAS and meet and exceed current safety levels in

relation to 14 C.F.R. §61.113 (a) & (b).d. D. 14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil

aircraft. It allows helicopters to be operated at lower altitudes in certain

conditions. My UAS will never operate at an altitude greater than 200 ft

AGL; safely below the standard of 400 AGL. I will also operate my UAS

in safe areas away from public and traffic, providing a level of safety at

least equivalent to or below those in relation to minimum safe altitudes.

Given the size, weight, maneuverability and speed of my UAS, an

equivalent or higher level of safety will be achieved.

e. E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b):

Maintenance Inspections.

The above-cited Regulations require, amongst other things, aircraft owners

and operators to “have [the] aircraft inspected as prescribed in subpart E of

this part and shall between required inspections, except as provided in

paragraph (c) of this section, have discrepancies repaired as prescribed in

part 43 of this chapter. . . ”

These Regulations only apply to aircraft with an airworthiness certificate.

They will not, therefore, apply to my UAS. However, as a safety

precaution I inspect my UAS before and after each flight.

A Summary the FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and

14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21,

Subpart H, entitled Airworthiness Certificates, sets forth requirements for

procurement of necessary airworthiness certificates in relation to FAR §

91.203(a)(1). The size, weight and enclosed operational area of my UAS permit

exemption from Part 21 because my UAS meets an equivalent level of safety
pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt

aircraft from the airworthiness certificate requirement under both the Act (49

U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation

permit the FAA to exempt UAS's from the airworthiness certificate requirement

in consideration of the weight, size, speed, maneuverability and proximity to areas

such as airports and dense populations. My UAS meets or exceeds each of the

elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an

airworthiness certificate. As no such certificate will be applicable in the form

contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b)

(2) requires an aircraft flight manual in the aircraft. As there are no pilots or

passengers, and given the size of the UAS's, this Regulation is inapplicable. An

equivalent level of safety will be achieved by maintaining a manual. The FAA has

previously issued exemptions to this regulation in Exemption Nos. 8607, 8737,

8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves

regular software updates and curative measures for any damaged hardware.

Therefore, an equivalent level of safety will be achieved.

In Summary:

I, Charles Rankin, respectfully request that the FAA grant my exemption

request and further volunteer any information gathered during flights in the event the

FAA is interested in live field data. I do agree and attest to adhere to any further

limitations the FAA imposes, now or in the future. Satisfaction of the current criteria

provided in Section 333 of the Reform Act of 2012 – size, weight, speed, operating

capabilities, proximity to airports and populated areas and operation within visual line of

sight and national security – provide more than adequate justification for the grant of the

requested exemptions allowing commercial operation of my UAS for commercial

purposes. I look forward to support the FAA and UAS community in its quest to establish

proper regulations and protocols for the safe introduction of unmanned aircraft into the

national airspace.

Sincerely,

Charles Rankin

1675 NC Hwy 42 

Goldston, NC. 27252