May 16 ,2015

U. S. Department of T ransport ation 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 o r Madam: P ursuant to the Section 333 of the FAA Modernization and Reform Act of20 12 (the "Reform Act"), Michael Watson ( th e "app li can t "), o perato r of an Unmanned Aircraft Systems ( " UAS") seeks an exemption f ro m the Federal Aviation Regu lation s ("FAR s" ) to allow for commerc ia l ope ration for ae r ial imaging and video of homes & properties applicant li st for sale in Central Oklahoma. Applicant Michae l Jay Watson 1 3508 R ed Cedar Dr. Oklahoma City , OK 7313 1
Attachments DJI Pi lot Training
Reg ulation s from whic h the exemption is requested: 1 4 CFR Part 21 s ubpart H 1 4 CFR 45.23 (b) 1 4 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 9 1. I 0 3 14 CFR 9 1. I 09 14 CFR 9 1.119 (c) 14 CFR 91.12 1 14 CF R 9 1. 203 (a) and (b) 1 4 CFR 9 1. 405 (a) 14 CFR 91.407 (a) (I) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) a nd (b)
Extent of relief I seek, and why 14 CFR Part 21 s ubpart H The UAs to be operated carries neither pilot nor passenger and carries no explosive material s or flammable liquid s. Given the s i ze, weight , speed, and limit ed operating area associated with the a ircraft to be ut ili zed, I requ est exception. In the restricted env ironment and under the conditions propo sed ope ration wi ll be at least a s s af e, or safer, than a conventional aircraft operating with an airworthiness certificat e witho ut said restric ti ons.
1 4 CFR 45.23 ( b) Due to the size of this UAS it does not have a cockpit, cabin , or pilo t s tati o n on w hi ch to ma rke t certain wo rds or phrases
. Lette ring would be very d ifficult to place on suc h a small aircraft and dimensions would need to be smaller than required minimum. Understanding the importance of lette rin g I will mark my UAS with the largest possible letters by placi ng th e word "Experimental" or assigned number or name , based o n request/ ruling ofF AA, on UAS fuselage. The equivalent leve l of sa fety will be provided by having t he UAS marked on it s fuse lage as requ ired.
14 CFR 9 1. 7 (a) As ther e will b e no airworthi ness certi ficate for the aircraft, s hould thi s exemption be gran ted, no FAA regulatory standard will ex is t for determin i n g a irworthiness. G iven the s ize of the ai rcraft formaintenance and u se of safe ty check li st prior to each fli g ht an e qui valent le\e l of safety will b e provided

. 14 CFR 91.9 (b) (2) Given the size and configu ration , the UAS has no abil it) to carr y a flight manual on the a ircr aft. There is no room , capaci t y, or pilot o n board to adequately carry fl ig ht manual. A equivalent le ve l of sa f ety w ill be maintained by keeping the flight manual at gro und cont ro l p o int w here the pilot will) have immedia te access to it.
14 CF R 91.103 A s FAA approved flight manual s will not b e provided for th e aircraft an exemption will be needed

. Normal procedures includin g but not lim ited to ; rev i ew in g weather , flight battery requirement, lan ding and take off di s tances , along will all of tho se found in att achment "D JI Pilot T raining"

. An equi val e nt level ofsafet) will be provided b y preflight protocol to prop e rl y matc h the machine

. 14 CFR 91.109 UAS and remotely piloted aircraft do not h a ve full y functional dual controls. Fli g ht contro l i s achieved throug h the u se of a con trol bo x th at co mmuni ca t es with the a irc raft via radio communication s. The equ ivalent l e\el of sa fety provided b ecause neit he r a pil ot no r passenge r will 

### be carried in the airc raft , and b y the s pee d and size of the aircraft.
14 CF R 9 1

. I 13 (a) and (b) I can achieve an equivalent level of safety as achieved by c urr e nt reg ulations becau se my UAS does not carry pilot nor pass enger. While help ful , a pil ots' license will no t ensure remote control pilotin g s kill s.
14 CFR 91.121 Th e UAS rna) no t have a barometric altime ter, but ins te ad doe s hav e a GPS altitud e read out. I believe an exemption may be needed. An equivalent level of sa fety is ac hieve by the operator receiving li ve flight data monitoring and confirming cu rrent altitude a lon g with altitude of laun c h s ite s hown on G P S altitud e indicator.
14 CF R 91.203 ( a ) and (b) S im i lar to , 14 CF R 91.9 (b ) (2) , given the size an d co nfi g uration, the UAS has no abi lit ) to carry certificate and regis tra tio n documents o n the airc raft. There is no room , capacity, or pilot on board to adequately such docum e nt s. An equivalent lev el of safety wi ll be achieve d by keeping th ese docum e nt s , t o the extent they are applicable to the UAS , at the ground contro l po i nt where pilot has imme diat e acce ss to t he m.
1 4 CF R 91.405 (a) , 14 CFR 91.407 (a) ( I ), 1 4 CFR 91.409 (a) (2) , 14 CFR 91.417 (a) and (b) Gi ve n th ese sec tion on!) app ly to a ircraft w ith an airwo rthine ss certi fic ate , the s e s se ction s do not a ppl y to thi s applicant. As a sa fety pre caution , operator will perform preflight inspections and en sure UAS i s in w o r king cond ition befo re in it iating each fl ig ht.
Michae l Watson is s eeking relief from a ll FARs above preven ting applicant from conducting ae r ial photograph y and video of real estate taken at lev e ls less t han 400ft , at a sp eed less than 33.5 mph , an d with a m axi mum flight time of25 minutes ,. The drone to b e used is a Dll Phantom 2 Plu s
. At 2 .7 4 pound s the weight of the UAS m ee t s the definition of " s mall unmanned aircraft" found in se ction 33 1 "The Reform Act". In order to obtain hi gh quality photography an d video the UAS will be u se d at speeds much less t han it's to p s peed of33.5 mph

. Due to the UAS b e in g battery po we red there are no combu st ible fuels o nboard

. Maximum flight time fo r t his p a rti c ular UAS is 25 minute s batteT) lif e, flig hts to be termin a ted with 25% battery lif e remaining

. Given th e size , weight , speed, and lim it ed op erating area ass ociated with the aircraft to be utili zed I find this exceptio n to be rea sonab le with an eq uivalent , o r g reater, level of s afet) to be reach e d b y the opera tor. Safety

* Please see attac hment "DJJ P ilot Trai nin g " for sa f ety precautio n s I u se for eveT) fligh t. A s ide f rom t hese Practices I was g iven a hand s on trainin g course when I purchased my U AS. Addi ti onally: I ) I do not operate within 5 mile s of an a irport unl es s prior contact to Air Tr af fic Contro l or the a irport
m a nager has been made

. 2) I land my UAS prior to manufacturer recommended minimum l eve l of battery powe r 3) I pilot my UAS through remote control by lin e of s i g ht

### 4) My UAS uses GPS and a fli g ht safety feature whereby it returns to a preprogrammed position and th e n slowly lands if communication with the remote control pilot is fost 5) l actively analyze fli g ht data and other source s of information to cons tantly 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 nec e ssary permissions prior to operation ; and , 8) I have procedures in place to abort flights in the event of safe!) breaches or potenti a l danger. 9 Public Interest The use of an UAS in the real estate industr y provides both buyers and sellers a higher level of servic e
. Fo r a buy er a higher leve l of marketin g and advertising is achieved , appeal ing to more buyers , resu lting in a quicker sale of their home. Quicker home sales also helps accelera t e the economy as a whole

. Buyers experience the benefit of encompassing a whole property , sometimes seve ral acres , in one photo or a short video. Not only does this benefit the specific home seller o r home buyer, but it benefits the general public because it is much more efficient than tradi t ional ways of u s ing 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 combustib le fu e ls , my UAS will poses much less of a safet; · concern for the general public when compared to larger manned aircraft

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### Michael Watson