# CHAMBERS 1857 Hwy 14:-.1 (:Orrdon,Iowa 3006(1 Auction

# & AppraisalCompany ()ffi(C641-872-2081 Pax 64J-8i2-1907



### US DepartmentofTransportation Docket Management System 1200 NewJerseyAvenue SE Washington, DC 20590 November20, 2015**~.** ; ; '



### RE: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe 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 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, Chambers Auction 

### &Appraisal Company, a real estate auction company and operatorofa small "quadcopter" (UAS) equipped for photos and videos ofproperties 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 underthe conditions outlined herein oras 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 forauction and forsale and to provide photos and videos to assist in property management, real estate appraisal, development and construction. The name and address ofthe 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 ofTransportation 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 controllerfor 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 transmitterto 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 quadcopterto hoverwhen no commands are being sent. 2. Non-GPS Modes
- IfGPS signals are lost or unavailable the aircraft uses P-OPTI or P-ATTl 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 lowor "fail safe" button is pushed on the transmitter. This is beneficial ifthe 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 concurrentlyto manageflight safety. The quadcopter is preprogrammed to not operate in a no fly zone or immediately land ifa no fly zone has been entered. 5. Aircraft status indicators- Give the userthe status ofthe aircraftthroughout 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 ofthe aircraftfrom the line ofsight. The aircraft status indicators are used to confirm the operation ofthe aircraft. The remote control transmitter offersfull telemetry showing altitude (with preset alarms of altitude and warnings when approaching 400' agl), as well as warnings for lowvoltage and signal strength, emergency return to home programed fail safe and emergency return to home button.US Department ofTransportation November20, 2015 Page3 Thevideo transmitter receiveroperatesat2.400 Ghz-2.483 Ghz. We understand it is legal to operate this without anyadditional licenses. Ifwe are incorrect, we will immediatelyapplyforall necessary licenses orchangeto a differentfrequency. (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 offlights will bewell belowthis limit at an average of 150' 200' AGLto accomplish the best photographs and videos. • Any required permits will be obtained from local and state governments beforeflights. • The aircraft will notoperate directly above human beings at anytime or within 150feet of human beings. • Maximum Flight Time will be 15 minutes. The battery allows 20 plus minutes offlight time. Batteries are inspected and always fully charged before use. • The aircraftwill notoperatewithin 5 miles ofan airport/heliportwithout prior approval from said airport/heliport. • All operations will be during the daytime and in ideal weather conditions of lessthan 15mph winds and clearskies. • Aircraftwill remain in visual line ofsite atall times notto exceed 

### V4 milefrom PIC. • Visual Observerwill serve as additional eyes on the aircraft and be within voice reach to communicate with the PIC. • Aircraft will notfly in the area ofanyfull scale aircraft and ifa full scale aircraft comes into airspace during the aircraft's flight, it will be landed immediatelyto allow right ofwayto full scale aircraft. • At anytime aircraft is being flown, signs will be posted in at leastthree (3) locations, warning of UAS operations are being conducted and to stay at least200' awayatall timesoflanding and takeoffarea (marked with a large orange cone). • The PIC, Jared Chambers, hasflown remote aircraft for 1.5 years. This has been exclusively multi-rotortypes such as the OJI Phantom (quadcopter). There have been no incidents of injury or property damage.US Department ofTransportation November20, 2015 Page 4

• TheApplicant believesthata private pilot's license is notapplicableto flying a UASfor several reasons (flight controls are differentthan a traditional aircraftand PIC holds a United States Passport, Iowa Concealed Weapons Permit, ClassA COL, and real estate licenses in Iowa and Missouri, and is a native born American which should satisfy anysuspicions ofbeing linked to Terrorism}. Although the PIC will obtain a private pilot's license within 120 days ofthe exemption being granted ifthe FAA deems it is indeed required. Ifthe FAA rules that a private pilot's license is not needed aftergranting the exemption and the PIC has not obtained a pilot's license atthat time, then PIC would request permission to not obtain a private pilot's license. • The UAS will never be used as an invasion ofprivacy and will only be used forthe purposes listed above. • Liability insurancewill 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 ofthe FAA Reform Act 

### & Part 11 ofthe Federal Aviation Regulations from 14C.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) 

### 14C.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 leasttwo "arms" ofthe 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 ofTransportation November20, 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 fordual 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 atraditional altimeter. It does howeverhave a barometrictype which displays the altitude on the transmitter ofwhich 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 offlight time with a 30% reserve of battery power. Ifthis level is reached the UAS returns to home and lands. However, no flight will last longerthan 15 minutes as an extra safety precaution. All batteries are only used iffreshly 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 ofTransportation November20, 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. IfApplicant's pre-flight checklist does not pass, the flight will be aborted. Any items ofconcern will promptly be repaired using similar components and records will be kept through maintenance records. Applicant is prepared to modify oramend any part ofthis petition for exemption to meet orexceed concerns ofsafety. Applicant does lookforward to working with the FAA to provide a great service to its community and profession in a safe manner. Upon receipt ofthis request, please date stamp the additional copy ofthe 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 ofthis request.

Jared Chambers Chambers Auction & Appraisal Company

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# CHAMBERS 1!\$7 Hwy l4 :ci CorydOfl. ioKJ 50fnlQ 

## 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 notwithin 5 Miles ofAirport/Heliport Ifso, call airport/heliportfor properauthority before flying. Record Contact Name, Phone, and Airport ifapproval is received Review Current Weather Conditions/Forecast as reported by the NWS Check all Battery Voltages/Condition- (if not charged, must charge before goingto location) Inspect all wires, plugs, and solder connections AT LOCATION Check BatteryVoltage 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 -Identifyany possible hazards such as phone poles, flag poles, utilitywires, flocks of birds, traffic, large groups of people etc. IdentifyTakeoffand Landing Location (same location) IdentifyVantage 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 forshot but never above 400' AGL • Every minute view telemetry data showing battery level and flighttime (flights are 15 minutes max) LANDING • Ensure Landing Area is clearfrom hazards orbystanders • View Wind Direction and Compensate Flight if needed • landAircraft- Motors are shut offimmediately after landing • Bystanders are not allowed to approach aircraft until battery has been disconnected EMERGENCY LANDING • Land immediately at asafe and close location when: o Other aircraft are spotted or heard (including other UAS) o Bystanders have gathered ora bystander has entered the proximity o Changes in weather orwind o Birds enteringthe 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:
---------------

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# CHAMBERS
Auction

## & AppraisalCompany

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 ofTest:------------------------ 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 ofa normal flight plan o Failure in eithertest flight will result in grounding ofthe 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