US Department of Transportation 

Docket Management System 

1200 New Jersey Avenue SE 

Washington DC 

20590 

Dear Sir or Madam: 

- f 

This petition is being submitted on my behalf without counsel or consulting 

services. 

Pursuant to section 333 of the FAA Modernization and reform Act of 2012 (the 

Reform Act) and 14 C.F.R Part 11, Donald D Bell, Realtor /Broker Beverly-Hanks 

and Associates, a full service real estate brokerage firm, hereby applies for an 

exemption from the Federal Aviation Regulations (FARS) listed below to allow 

operation of my Small Unmanned Aircraft System (sUAS) commercially in airspace 

regulated by the Federal Aviation Administration (FAA) so long as such operations 

are conducted with and under the conditions outlined herein or as may be 

established by the FAA as required by section 333. 

THE requested exemption would permit Donald D Bell to pursue its commercial 

interests in providing services to clients and for marketing purposes using a small 

advanced sUAS in the following areas: 

1. Real Estate 

2. Marketing of Real Estate 

3. Photography of land for the sellers and buyers visual knowledge 

4. 

Donald D Bell states that all sUAS flights will occur over private or controlled access 

property and will do so with the property owners consent and knowledge and that 

only people who have consented or otherwise have agreed to be in the area where 

aerial videographer and photography will take place. 
REGULATIONS FROM WHICH EXEMPTION IS REQUESTED: 

14 C.F.R Part 21 

14 C.F.R. 45.23(b) 

14 C.F.R. 61.113(a) & (b) 

14 C.F.R. 91.7 (a) 

14 C.F.R. 91.9 (b) (2) 

14 C.F.R. 91.109 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R. 91.151 (a) 

14 C.F.R. 91.203 (a) & (b) 

14 C.F.R. 91.205 (b) 

14 C.F.R. 91.215 

14 C.F.R. 91.401-91.417 

Unmanned Aircraft System 

sUAS are often seen as superior to helicopters as an aerial video gathering platform 

due to the small devices cheaper equipment and personal cost. Couple that with the 

greater degree of mobility for photography in areas where it is virtually impossible 

to take any quality of photos to share with the client or prospective buyer. 

Donald D Bell is petitioning for an exemption to operate a DJI Phantom 2 Vision Plus. 

This sUAS features are as follows: 

3-AXIS CAMERA STABILIZATION 

A built-in high precision 3-axis camera stabilization system brings a whole new 

level of smoothness to your aerials and gives you total creative freedom in the sky. 

PRECISION FLIGHT AND STABLE HOVERING 

The integrated GPS auto-pilot system offers position holding, altitude Jock and 

stable hovering, giving you constant smooth flight so you can focus on getting the 

shots you want. 

GROUND STATION SUPPORT 

Program a flight path using your smart-phone with our I 6 waypoint Ground 

Station system. Tilt the camera up and down, take photos and shoot video all while 

the Phantom 2 Vision+ flies autonomously. 
ONSCREEN REAL-TIME FLIGHT PARAMETERS 

Keep track of current flight telemetry and see what your Phantom sees on your 

mobile device. 

HIGH PERFORMANCE CAMERA 

The Phantom 2 Vision+ carries an extremely high quality camera and a removable 

4GB micro SD card. It shoots full HD video at I 080p/30fps and 720p/60fps, 

giving you crystal clear video and the option for slow motion shots. Photos are 

shot at 14 megapixels. 

CAMERA TILT CONTROL 

Tilt the camera as you fly, creating unique angles and amazing shots. 

SUPPORTS ADOBE DNG RAW 

DNG RAW photo capture means all original image information is retained for 

powerful post processing. 

ADOBE LENS PROFILE SUPPORT 

An Adobe lens profile for barrel distortion removal is available for the DJI 

Phantom 2 Vision+ camera. 

CAMERA PARAMETER SETTINGS 

Camera settings including Picture Quality, ISO, Exposure Compensation, White 

Balance, and capture Format can be adjusted through the VISION app. 

ALBUM SYNCHRONIZATION 

Beam photos and videos from the Vision+ straight to your phone using Wi-Fi. No 

computer required. 

The flight radar displays the current position of the Phanton1 

2 Vision+ in relation to the pilot. 

Exceeding the control range of the remote control will trigger 

'Return-to-Home', meaning the Phantom 2 Vision+ will 

aut01natically fly back to its takeoff point and land safely. 

The DJI product also offers a failsafe in that if the unit looses 

contact with the ground station the DJI Phantom Vision 2 Plus will 

autotnatically return to home base launce site. This is also a feature 

in the event that the batter reaches end of charge. ( 25 minute 

normal flight time on one charge) 
Additional specifications: 

A.ircraft 

Supported Battery 

DJI 5200mAh LiPo Battery 

Weight (Battery & Propellers Included) 

1242g 

Hover Accuracy (Ready To Fly) 

Vertical: 0.8m; Horizontal: 2.5m 

\1ax Yaw Angular Velocity 

W0°1S 

\1ax Til table Angle 

35° 

\1ax Ascent I Descent Speed 

<\scent: 6mls; Descent: 2mls 

\1ax Flight Speed 

15mls (Not Recommended) 

Diagonal Motor-Motor Distance 

350mm 

Gimbal 

Working Current 

Static: 750mA; Dynamic : 900mA 

Control Accuracy 

±0.03° 

Controllable Range 

Pitch : -90°1110° 

Maximum Angular Speed 

Pitch: 90°ls 
Camera 

Operating Environment Temperature 

0°C-40°C 

Sensor Size 

1/2.3" 

Effective Pixels 

!4 Megapixels 

Resolution 

4384x3288 

Hd Recording 

I 080p30 & 720p 

Recording Fov 

110° I 85° 

Remote Control 

Operating Frequency 

5.728 GHzlll5.85 GHz 

Communication Distance (Open Area) 

CE Compliance: 400m; FCC Compliance: 800m 

Receiver Sensitivity (I %Per) 

-93dBm 

Transmitter Power 

CE Compliance: 25m W; FCC Compliance: I OOm W 

Working Voltage 

120 mA@3.7V 

Built-In Lipo Battery Working Current/Capacity 

3 .7V, 2000mAh 

Range Extender 

Operating Frequency 

24 I 2-2462MHz 

Communication Distance (Open Area) 

500-700m 

Transmitter Power 

20dBm 

Power Consumption 

2W 
DJI VISION App 

System Requirement Of Mobile Device 

iOS version 6.1 or above/ Android system version 4.0 or above 

Mobile Device Support 

• iOS recommended: iPhone 4s, iPhone 5, iPhone 5s, iPhone 6, iPhone 6 Plus, 

• iPod touch 5 (available but not recommended: iPad 3, iPad 4, iPad mini) 

• Android recommended: Samsung Galaxy S3, S4, Note 2, Note 3 or phones of similar configuration 

These specifications meet with the Model Aircraft Operation Standards as set below: 

1. The petitioner will only operate its sUAS in the line-of-sight of a pilot and for 

observer and will operate at sites that are" sufficient distance" for populated 

areas within sterile area described in the FOPM. Such operations will ensure 

the sUAS will not "create a hazard to users of the national aerospace systems 

or the public." 

2. When flying the sUAS within (3) miles of an airport, airport operators will be 

notified and the operator will give the right-of-way to avoid flying in the 

proximity of full-scale aircraft. Maximum flight time for each operation will 

be 30 minutes. 

3. Flights will be terminated when the batter reaches 25%, allowing sufficient 

reserve flight time to saftly land the sUAS. 

4. The sUAS will be programmed so it will not operate at an altitude that 

exceeds 400 feet AGL and not more than 200 feet above an elevated platform 

from which videographer is planned. 

5. Minimum crew for each operation shall consist of: sUAS pilot, (Pilot in 

charge or PIC) a visual sUAS observer (Visual Observer or VO) 

and the camera operator. 

6. The sUAS operated by the petitioner weighs less than 25 Lbs including all 

payload ( camera, lens, and stabilized gimbal ) 

7. The sUAs will operate at speeds of no greater that 1Smjs, can hover and can 

simultaneously move vertically and horizontally. 

8. Because of the size of the sUAS and the restricted sterile environment within 

which it operates, Donald D Bell operations adhere to the Reform Act's safety 

requirement. 

9. The PIC will have logged at least 20hrs before authorization to fly 

10. All flights will be placed in an active log. 

11. All flights will occur under Visual Flight rules Meteorological Conditions ( 

VMG) only. 

12. The PIC and VO will have been trained in operation of sUAS and received upto-date information for the particular sUAS operated. 
In addition to those items stated it is my sincere opinion that by granting this exemption would 

allow both buyer and sellers to get a clear and concise view of property they own or will own 

without the sometimes hazardous walking about unknown terrain. In the mountains of western 

North Carolina we regularly encounter treacherous terrain as well as wildlife that may harm or 

be harmed by traditional walking of land. For example: black bear sow and cubs in the spring, 

rattle snake and copper head snake, to mention a few. 

When videoing or photographing a tract, as stated in the bullet point, we will have enough 

coverage from the PIC or the VO to protect the general public and generally speaking we will be 

flying tracts that are larger than 10 acres. That limits the general public interaction. 

I also believe that by granting my request it will allow a great deal of flexibility in my practice in 

the land brokerage business to have a smaller footprint on the land as well as a small 

environmental impact. 
The applicant Donald D Bell, believes this exemption request and associated safety 

considerations adequately satisfy criteria provided in Section 333 of the Reform Act 

of 2012, providing sufficient justification for the granting of commercial operations 

of the applicant's sUAS. 

The applicant, Donald D Bell, request your respective approval under this Section 

333 exemption petition request. 

Thank you for your interest and consideration in this matter. Please notify Donald D 

Bell of your actions, and or approvals. 

R~y{Jflll! 

Donald D Bell 

dbell(dJbeverly-hanks.com 

9 Cleftridge Court 

Asheville NC 28803 

828-275-8286 

Beverly-Hanks and Associates 

820 Merriman Ave 

Asheville NC 

28804