May 16,2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., 

Washington, DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act and Part II of the Federal Aviation 

Regulations 

Dear Sir or Madam: 

Pursuant to the Section 333 of the FAA Modernization and Reform Act of20 12 (the "Reform Act"), Michael 

Watson (the "applicant"), operator of an Unmanned Aircraft Systems ("UAS") seeks an exemption from 

the Federal Aviation Regulations ("FARs") to allow for commercial operation for aerial imaging and video 

of homes & properties applicant list for sale in Central Oklahoma. 

Applicant 

Michael Jay Watson 

13508 Red Cedar Dr. 

Oklahoma City, OK 7313 1 

Attachments 

DJI Pilot Training 

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 9 1. I 03 

14 CFR 9 1. I 09 

14 CFR 9 1.119 (c) 

14 CFR 91.12 1 

14 CFR 91.203 (a) and (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (I) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) and (b) 

Extent of relief I seek, and why 

14 CFR Part 21 subpart H 

The UAs to be operated carries neither pilot nor passenger and carries no explosive materials or 

flammable liquids. Given the size, weight, speed, and limited operating area associated with the aircraft 

to be utilized, I request exception. In the restricted environment and under the conditions proposed 

operation will be at least as safe, or safer, than a conventional aircraft operating with an airworthiness 

certificate without said restrictions. 

14 CFR 45.23 (b) 

Due to the size of this UAS it does not have a cockpit, cabin, or pilot station on which to market certain 

words or phrases. Lettering would be very difficult to place on such a small aircraft and dimensions 

would need to be smaller than required minimum. Understanding the importance of lettering I will mark 

my UAS with the largest possible letters by placing the word "Experimental" or assigned number or 

name, based on request/ruling ofF AA, on UAS fuselage. The equivalent level of safety will be provided 

by having the UAS marked on its fuselage as required. 

14 CFR 9 1.7 (a) 

As there will be no airworthiness certificate for the aircraft, should this exemption be granted, no FAA 

regulatory standard will exist for determining airworthiness. Given the size of the aircraft for 
maintenance and use of safety check list prior to each flight an equivalent le\el of safety will be 

provided. 

14 CFR 91.9 (b) (2) 

Given the size and configuration, the UAS has no abilit) to carry a flight manual on the a ircraft. There is 

no room, capacity, or pilot on board to adequately carry flight manual. A equivalent level of safety will 

be maintained by keeping the flight manual at ground control point where the pilot will) have immediate 

access to it. 

14 CFR 91.103 

As FAA approved flight manuals will not be provided for the aircraft an exemption will be needed. 

Normal procedures including but not limited to; reviewing weather, flight battery requirement, landing 

and takeoff distances, along will all of those found in attachment "DJI Pilot Training". An equivalent level 

ofsafet) will be provided by preflight protocol to properly match the machine. 

14 CFR 91.109 

UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved 

through the use of a control box that communicates with the aircraft via radio communications. The 

equivalent le\el of safety provided because neither a pilot nor passenger will be carried in the aircraft, 

and by the speed and size of the aircraft. 

14 CFR 91. I 13 (a) and (b) 

I can achieve an equivalent level of safety as achieved by current regulations because my UAS does not 

carry pilot nor passenger. While helpful, a pilots' license will not ensure remote control piloting skills. 

14 CFR 91.121 

The UAS rna) not have a barometric altimeter, but instead does have a GPS altitude read out. I believe 

an exemption may be needed. An equivalent level of safety is achieve by the operator receiving live 

flight data monitoring and confirming current altitude along with altitude of launch site shown on GPS 

altitude indicator. 

14 CFR 91.203 (a) and (b) 

Similar to, 14 CFR 91.9 (b) (2), given the size and configuration, the UAS has no abilit) to carry certificate 

and registration documents on the aircraft. There is no room, capacity, or pilot on board to adequately 

such documents. An equivalent level of safety will be achieved by keeping these documents, to the 

extent they are applicable to the UAS, at the ground control point where pilot has immediate access to 

them. 

14 CFR 91.405 (a), 14 CFR 91.407 (a) ( I), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (a) and (b) 

Given these section on!) apply to aircraft with an airworthiness certificate, theses sections do not apply 

to this applicant. As a safety precaution, operator will perform preflight inspections and ensure UAS is in 

working condition before initiating each flight. 

Michael Watson is seeking relief from all FARs above preventing applicant from conducting aerial 

photography and video of real estate taken at levels less than 400ft, at a speed less than 33.5 mph, and 

with a maximum flight time of25 minutes,. The drone to be used is a Dll Phantom 2 Plus. At 2.74 

pounds the weight of the UAS meets the definition of "small unmanned aircraft" found in section 331 

"The Reform Act". In order to obtain high quality photography and video the UAS will be used at speeds 

much less than it's top speed of33.5 mph. Due to the UAS being battery powered there are no 

combustible fuels on board. Maximum flight time for this particular UAS is 25 minutes batteT) life, flights 

to be terminated with 25% battery life remaining. Given the size, weight, speed, and limited operating 

area associated with the aircraft to be utilized I find this exception to be reasonable with an equivalent, 

or greater, level of safet) to be reached by the operator. 

Safety 

*Please see attachment "DJJ Pilot Training" for safety precautions I use for eveT) flight. Aside from these 

Practices I was given a hands on training course when I purchased my UAS. 

Additionally: 

I) I do not operate within 5 miles of an airport unless prior contact to Air Traffic Control or the airport 

manager has been made. 

2) I land my UAS prior to manufacturer recommended minimum level of battery power 

3) I pilot my UAS through remote control by line of sight 
4) My UAS uses GPS and a flight safety feature whereby it returns to a preprogrammed position and 

then slowly lands if communication with the remote control pilot is fost 

5) l actively analyze flight data and other sources of information to constantly update and enhance 

safety protocol - s 

6) I conduct extensive pre-flight inspections and protocol, during which safety carries primary 

importance 

7) I always obtain all necessary permissions prior to operation; and, 

8) I have procedures in place to abort flights in the event of safe!) breaches or potential danger. 

9 

Public Interest 

The use of an UAS in the real estate industry provides both buyers and sellers a higher level of service. 

For a buyer a higher level of marketing and advertising is achieved, appealing to more buyers, resulting 

in a quicker sale of their home. Quicker home sales also helps accelerate the economy as a whole. 

Buyers experience the benefit of encompassing a whole property, sometimes several acres, in one 

photo or a short video. Not only does this benefit the specific home seller or home buyer, but it benefits 

the general public because it is much more efficient than traditional ways of using a plane or helicopter 

to achieve the same result. We can now provide this level of service while being conservative with fuel, 

time, emissions, noise, and other resources. Considering size, weight, speed, and absence of 

combustible fuels, my UAS will poses much less of a safet;· concern for the general public when 

compared to larger manned aircraft. 

Michael Watson