CHAMBERS 1857 Hwy 14:-.1 

( :Orrdon, Iowa 3006(1 

Auction & Appraisal Company 

()ffi(C 641-872-2081 

Pax 64J-8i2-1907 

US Department of Transportation 

Docket Management System 

1200 New Jersey Avenue SE 

Washington, DC 20590 

November 20, 2015 

~. 

; ; ' 

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from 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); 91.103(b); 91.109; 91.119; 91.121; 

91.151 (a); 91.203(a) & (b); 91.405(a); 91.407(a)(1 ); 91.409; 91.417(a) & {b) 

Ladies and Gentlemen: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

Reform Act) and 14 C.F.R. Part 11, Chambers Auction & Appraisal Company, a real 

estate auction company and operator of a small "quadcopter" (UAS) equipped for photos 

and videos of properties primarily in the south central Iowa area, hereby applies for an 

exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial 

operation of its UASs, so long as such operations are conducted within and under the 

conditions outlined herein or as may be established by the FAA as required by Section 

333. 

The purpose of proposed flights are to provide photos and videos of real estate 

offered for auction and for sale and to provide photos and videos to assist in property 

management, real estate appraisal, development and construction. 

The name and address of the applicant is: 

Chambers Auction & Appraisal Company 

ATTN: Jared Chambers 

1857 Hwy 14 North 

Corydon, Iowa 50060 

Telephone No. 641-414-0234 

Email: jared@chambersauction.com 
US Department of Transportation 

November 20, 2015 

Page 2 

The UAS and flights 

The UAS is a 2.8 lb battery powered quadcopter (four motors, four blades), a 

handheld remote controller for control, associated control receivers on the aircraft, 

camera gimbal with Sony EXMOR 1/2.3" Effective Pixels: 12.4M (total pixels: 12.76M) 

and video transmitter to a small 2.5" x 5" screen for camera shot placement only (UAS is 

controlled only by line of sight). The aircraft is equipped with a flight controller on board 

the UAS. The controller offers the following: 

1. GPS Assisted Flight - GPS allows the quadcopter to hover when no 

commands are being sent. 

2. Non-GPS Modes - If GPS signals are lost or unavailable the aircraft uses 

P-OPTI or P-A TTl to monitor the altitude and provide control assistance to 

help keep the aircraft stable and under control. 

3. Return to Home - Allows the quadcopter to return to home and land when 

battery power is low or "fail safe" button is pushed on the transmitter. This 

is beneficial if the pilot becomes disoriented or there are battery issues. 

4. The remote controller comes with preprogrammed flight limitations, 

including height limits, distance limits, and no fly zones. These function 

concurrently to manage flight safety. The quadcopter is pre programmed to 

not operate in a no fly zone or immediately land if a no fly zone has been 

entered. 

5. Aircraft status indicators- Give the user the status of the aircraft throughout 

different sequences of blinking lights and/or alarms. 

The Phantom 3 Professional Quick Start Guide and User Manual are included for review 

with this packet. 

The UAS also has front LEOs and aircraft status indicators. The LEOs are used 

for orientation and location of the aircraft from the line of sight. The aircraft status 

indicators are used to confirm the operation of the aircraft. 

The remote control transmitter offers full telemetry showing altitude (with preset alarms of 

altitude and warnings when approaching 400' agl), as well as warnings for low voltage 

and signal strength, emergency return to home programed fail safe and emergency return 

to home button. 
US Department of Transportation 

November 20, 2015 

Page3 

The video transmitter receiver operates at 2.400 Ghz-2.483 Ghz. We understand 

it is legal to operate this without any additional licenses. If we are incorrect, we will 

immediately apply for all necessary licenses or change to a different frequency. (Photos 

are included as Exhibit "A"). 

The UAS will be flown with a pilot in command (PIC) and a ground based visual 

observer (VO) in accordance with FAA Policy N 8900.227 Section 14 "Operational 

Requirements for UAS" with the following additional restrictions: 

• All operations will occur in Class G airspace at no more than 400' AGL. 

The vast majority of flights will be well below this limit at an average of 150' 

200' AGL to accomplish the best photographs and videos. 

• Any required permits will be obtained from local and state governments 

before flights. 

• The aircraft will not operate directly above human beings at any time or 

within 150 feet of human beings. 

• Maximum Flight Time will be 15 minutes. The battery allows 20 plus 

minutes of flight time. Batteries are inspected and always fully charged 

before use. 

• The aircraft will not operate within 5 miles of an airport/heliport without prior 

approval from said airport/heliport. 

• All operations will be during the daytime and in ideal weather conditions of 

less than 15mph winds and clear skies. 

• Aircraft will remain in visual line of site at all times not to exceed V4 mile from 

PIC. 

• Visual Observer will serve as additional eyes on the aircraft and be within 

voice reach to communicate with the PIC. 

• Aircraft will not fly in the area of any full scale aircraft and if a full scale 

aircraft comes into airspace during the aircraft's flight, it will be landed 

immediately to allow right of way to full scale aircraft. 

• At any time aircraft is being flown, signs will be posted in at least three (3) 

locations, warning of UAS operations are being conducted and to stay at 

least 200' away at all times of landing and takeoff area (marked with a large 

orange cone). 

• The PIC, Jared Chambers, has flown remote aircraft for 1.5 years. This 

has been exclusively multi-rotor types such as the OJI Phantom 

( quadcopter). There have been no incidents of injury or property damage. 
US Department of Transportation 

November 20, 2015 

Page 4 

• The Applicant believes that a private pilot's license is not applicable to flying 

a UAS for several reasons (flight controls are different than a traditional 

aircraft and PIC holds a United States Passport, Iowa Concealed Weapons 

Permit, Class A COL, and real estate licenses in Iowa and Missouri, and is a 

native born American which should satisfy any suspicions of being linked to 

Terrorism}. Although the PIC will obtain a private pilot's license within 120 

days of the exemption being granted if the FAA deems it is indeed required. 

If the FAA rules that a private pilot's license is not needed after granting the 

exemption and the PIC has not obtained a pilot's license at that time, then 

PIC would request permission to not obtain a private pilot's license. 

• The UAS will never be used as an invasion of privacy and will only be used 

for the purposes listed above. 

• Liability insurance will be maintained at all times. 

• Applicant's equipment is not inexpensive and Applicant takes public and 

property safety seriously. Applicant has developed pre-flight plans, flight 

plans and emergency procedures and maintenance procedures. 

Exemptions 

Exemption Request Section 333 of the FAA Reform Act & Part 11 of the Federal Aviation 

Regulations from 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 }; 91.1 03(b }; 91.1 09; 91.119; 91.121; 91.151 (a); 91.203(a) & {b); 

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

14 C.F.R. Part 21, 45.29, 45.23: 

The aircraft has no area to display numbers or letters that are at least 2" in size. To 

Applicant's knowledge there is no Registration System for UAS. Applicant will place in 

the largest letters possible "Chambers Auction & Appraisal Company" on at least two 

"arms" of the craft. 

14. C.F.R. 91.7: 

To Applicant's knowledge there is no aircraft airworthiness certificates for UAS. 

Applicant will before each flight run through the enclosed pre-flight checklist to ensure 

airworthiness. 

14 C.F.R. 91.9(b) 

There is no cockpit to include said manual. Operating manual will be kept with PIC. 
US Department of Transportation 

November 20, 2015 

Page 5 

14 C.F.R. 91.103: 

Since there will not be a· FAA approved quadcopter manual to be provided Applicant will 

need to be exempt. Applicant will again follow its enclosed pre-flight checklist to ensure 

safety and airworthiness. 

14 C.F.R. 91.109: 

UAS are controlled by a transmitter and do not have the capability for dual controls. It is 

Applicant's understanding there have been other aircraft approved without dual controls. 

14 C.F.R. 91.119: 

Since flights will never be above 400' AGL and usually 150' to 200' AGL, Applicant 

requests an exemption as the altitudes cited in 14 C.F.R. 91.119 would cause us to 

exceed said 400' AGL. 

14 C.F.R. 91.121: 

UAS does not have a traditional altimeter. It does however have a barometric type which 

displays the altitude on the transmitter of which is monitored at all times to prevent 

exceeding 400' AGL. There is also an alarm on the transmitter when reaching within 50' 

of400' AGL. 

14 C.F.R. 91.151: 

The UAS does not use traditional fuel but rather battery power. The battery provides for 

up to 18 minutes plus of flight time with a 30% reserve of battery power. If this level is 

reached the UAS returns to home and lands. However, no flight will last longer than 15 

minutes as an extra safety precaution. 

All batteries are only used if freshly charged. All batteries are visually inspected and volt 

tested before each flight. 

14 C.F.R. 91.203: 

There is no cockpit to include said certificates or registration documents. Any 

certificates, exemptions or registration documents will be with the PIC on the ground 

level. 
US Department of Transportation 

November 20, 2015 

Page 6 

14 C.F.R. 91.405, 91.407, 91.409, 91.417: 

As there is no airworthiness inspections available Applicant requests an exemption. 

Again Applicant will perform pre-flight checklists to ensure safety. 

If Applicant's pre-flight checklist does not pass, the flight will be aborted. 

Any items of concern will promptly be repaired using similar components and records will 

be kept through maintenance records. 

Applicant is prepared to modify or amend any part of this petition for exemption to 

meet or exceed concerns of safety. Applicant does look forward to working with the FAA 

to provide a great service to its community and profession in a safe manner. Upon 

receipt of this request, please date stamp the additional copy of the first and last page of 

this letter and return it to me in the self addressed, stamped envelope also enclosed. 

Thank you in advance for your consideration of this request. 

Jared Chambers 

Chambers Auction & 

Appraisal Company 
CHAMBERS 

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UAV Pre-Flight/Flight Plan Checklist 

Auction & Appraisal Company Ofli<'~ M 1·1!71·~0~2 F,l>:MJ-872·2907 

Date:----------

Name: ___________________ ObseNer: _____________________ _ 

(Person in Control) 

Flight Location:----------------------------------

Weather Condition/Visibility/Wind Speed:----------------------

BEFORE LOCATION 

Ensure Flight Location is not within 5 Miles of Airport/Heliport If so, call airport/heliport for proper authority before 

flying. Record Contact Name, Phone, and Airport if approval is received 

Review Current Weather Conditions/Forecast as reported by the NWS 

Check all Battery Voltages/Condition- (if not charged, must charge before going to location) 

Inspect all wires, plugs, and solder connections 

AT LOCATION 

Check Battery Voltage and Visual Inspection of Battery 

Inspect Props on UAS for cracks, loose securing screws/bolts, proper rotation 

Visually Re-check Current Weather Conditions 

Site SuNey -Identify any possible hazards such as phone poles, flag poles, utility wires, flocks of birds, traffic, large 

groups of people etc. 

Identify Takeoff and Landing Location (same location) 

Identify Vantage Points for PIC and ObseNer 

Ensure before motors are armed, no one is in hazard area 

DURING FLIGHT 

• Remain Alert for Possible Aircraft, Bystanders, or other hazards such as changing weather or birds 

• Fly only as high as needed for shot but never above 400' AGL 

• Every minute view telemetry data showing battery level and flight time (flights are 15 minutes max) 

LANDING 

• Ensure Landing Area is clear from hazards or bystanders 

• View Wind Direction and Compensate Flight if needed 

• land Aircraft- Motors are shut off immediately after landing 

• Bystanders are not allowed to approach aircraft until battery has been disconnected 

EMERGENCY LANDING 

• Land immediately at a safe and close location when: 

o Other aircraft are spotted or heard (including other UAS) 

o Bystanders have gathered or a bystander has entered the proximity 

o Changes in weather or wind 

o Birds entering the area 

o Anything happens to distract pilot 

o If PIC feels uncomfortable for any reason 

Flight was performed to all flight plans and protocols contained herein: (sign below) 

PIC: ------------------Observer: ---------------
CHAMBERS 

~ 

Auction & Appraisal Company 

Date:-------

I~,;; HIIIV 14 N 

Cr>r)'don: I<J""J ;:;0060 

Office 64.1·Ri2·.20lll 

Pax IHI-872-2901 

UAV Maintenance & Repair Report 

Person Performing Maintenance:-------------------------

Reason for Maintenance or Repair: 

Part(s} Being Replaced/Repaired (including any manufacturer information}: 

After Maintenance/Repair: 

• Test Flight to be Performed in Ultra Safe Zone: 

o location of Test:------------------------

0 Date:--------

• Tests to be Performed: 

o low Hover, low Flight Control Test (in all flight modes) 

o If Passed- 2nd Test Flight will be of a normal flight plan 

o Failure in either test flight will result in grounding of the aircraft until proper repair can be completed 

Sign: (PIC} 

Sign: (Observer) 
DJI Phantom 3 Professional 

4KCamera 

On Front 

EXHIBIT 

A 
DJI Phantom 3 Professional 

Flight Control Transmitter 

Flight Control Transmitter 
DJI Phantom 3 Professional 

Removable Battery