Ross Wheeler

Solutions Property Management
3220 S Western Ave Sioux F a lls, SD 57105 Direct 605

- 988

- 8509
Fax 605

- 370

- 6588

Ma y 11 th 2015

U.S. Department of Transportation Docket Operations 1200 New Jersey Avenue, SE Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. Part 21, 45.27(a), 45.29 (3) (c)(d) (e )(f)(g)(h), 61.113 (a) & (b), 91.103,91.121,91.203, 901.151

Following the format of FAA exemption No. 11138

- Regulatory Docket No. FAA

– 2014

- 0481 I have included:

1. Supplement Response for Petition
2. Phantom Flying Flow Char t 3. Phantom Qui ck Start Manual
4. Phantom 2 Vision User Manual

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C FR Part 11, I, Ross Wheeler, a licensed Broker Associate and certified private pilot (certificate # 3218249 ) ( current 3 rd class medical certificate ) would like to apply for an exemption from the following Code of Federal Regulations (CFR) to be allowed com mercial operation of a lightweight Unmanned Aircraft System s (UAS) for aerial imaging and video of properties I manage and list for sale.

I am new to flying drones, however I have nearly 300 hours of PIC time in a fixed wing aircraft. I als o have countless hours of RC airplane hours for as a hobby. Our office recently added the DJ I Phantom 2 Vision quad

- copter ( weighing less than 3 pounds), equipped with the included camera

. My intent is to capturing aerial p hotos/videos to supplement the properties we manage and real estate listings; following exemption and approval by the FAA.

My exemption request would permit operation of ultra

- light weight, unmanned (piloted be remote control) in predetermined a reas away from general public, airports, heliports and vehicular traffic , under2 00 ft (AGL) and afte r reviewing the flight path of aerial observation. I will operate in a safe environment

that is strictly controlled away from power lines, elevated lights, airpo r ts and actively populated areas . I will personally conduct extensive preflight inspections and implement the same p rotocols I perform during my fixed wing flights. I will also check weather and will not fly in adverse weather. I shall abide all FAA requirements to ensure this exemption will provide the high est level of safety

. 14 CFR Part 21, subpa rt H: Airworthiness Certificates § 14 CFR 91.203

Given the size, weight, speed and limited operating area associated with the aircraft to be utilized, I am requesting exemption from 14 CFR part 21, Subpart H ( Airwo rthiness certifications) and § 91.203 (a) and (b), subject to certain conditions and limitation, is warranted and meets the requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of PL 112

- 95 (Section 333).

14 CFR 45.27 (a): Location of marks; non fixed

- wing aircraft. 14 CFR 45.29 (3)(c)(d)(e) (f)(h): Size of Marks

Furthermore I request an exemption from §45.23 Marking of the aircraft because my UAS will not have a cabin, cockpit, or pilot station on which t o mark certain words or phrases. Additionally two

– inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. I understand the need for markings and will mark my UAS in the larges possible lettering and if required by the FAA I will place the necessary markings, name or numbers to my UAS.

I also ask for an exemption from §91.405(a), 91.407(a)(1), 91.409(a)(2) an 91.417(a) and (b)
Maintenance inspections may be required and should be granted since they only apply to aircraft with an airworthiness certificate

. But, as a safety precaution I will perform a preflight inspection of my UAS before each flight as outlined in its operating d ocuments.

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: pilot in command (PIC)

Under §61.113 (a) and (b) private pilots are limited to non

- commercial operations, however I can achieve an equivalent level of sa fety as achieved by current regulations because my UAS does not car r y and pilots, passengers or cargo. The risks of operating a UAS are far less than the risk levels inherent in the commercial activities outlined in 14 CFR Part 61. As a certified private pilot, I understand the rules and regulations of the FAA and that safety is top priority.

14 CFR 91.103 (b)(1), (b)(2): Pr eflight Action

If granted an exemption I agree to additional safety procedures including, but not limited to:

1. Keeping my UAS within a radius of 500 feet from the controller to both aid in direct line of sigh visual observation.
2. Operate the UAS for 10

- 15 m inutes per flight : land my UAS according to the SOPs and minimum battery power.
3. Operate my UAS only within visual line of sight and during daylight hours.4. Use the UAS GPS system, a flight safety feature that slowly lands the aircraft when

co mmunication is lost.
5. Make sure all software for the UAS is up to date and firmware is functioning properly.
6. Contact Air Traffic Control (ATC) for every flight within clas s (D) airspace. I will relay all my intentions and flight information.
7. Have procedures in place to abort flights in the event of safety breaches or potential harm.

Aerial videography for geographical awareness of real estate marketing ha s been around for a long time through manned fixed winged aircraft and helicopters, but for small business owners its expense has been cost

- prohibitive. Granting this exemption would allow me to provide this service at a much lower cost. Further, my small UAS when used properly will pose no threat to the general public given it s small size and lack of combustible fuel when compared to larger manned aircraft. The operation of this UAS will minimize ecological damage and promote economic growth by providing information to companies looking to lease spaces to lease or building in the Sioux Falls area.